IDAPA 35.01.01.331 — APPORTIONABLE AND NONAPPORTIONABLE INCOME DEFINED: APPORTIONABLE

INCOME (RULE 331).
Section 63-3027(a)(1), Idaho Code
01.
In General. Apportionable income means income of any type or class and from any activity that
meets the "transactional test" described in Rule 332 of these rules, or the "functional test" described in Rule 333 of
these rules. The classification of income by the labels occasionally used, such as manufacturing income,
compensation for services, sales income, interest, dividends, rents, royalties, gains, operating income, and
nonoperating income, is of no aid in determining whether income is apportionable or nonapportionable income.
(4-6-23)
02.
Terms Used in Definition of Apportionable Income and in Application of Definition. As used
in the definition of apportionable income and in the application of the definition.
(4-6-23)
a.
"Trade or business" means the unitary business of the taxpayer, part of which is conducted within
Idaho.
(4-6-23)
b.
"To contribute materially" includes, without limitation, "to be used operationally in the taxpayer's
trade or business." Whether property materially contributes is not determined by reference to the property's value or
percentage of use. If an item of property materially contributes to the taxpayer's trade or business, the attributes,
rights or components of that property are also operationally used in that business. However, property that is held for
mere financial betterment is not operationally used in the taxpayer's trade or business.
(4-6-23)