Dow Chemical Co. v. Director of Revenue, State

CHARLES SHANGLER, Special Judge.

Dow Chemical Company, a Delaware corporation with headquarters in Michigan, operates an international as well as interstate business that includes Missouri. Dow elected to use the three-factor apportionment ratio of the Multistate Tax Compact, § 32.200, art. Ill, IV, RSMo 1986, to derive its Missouri taxable income. In its Missouri tax returns for years 1975 through 1980, Dow excluded from apportionment certain corporate income, deemed as dividends for purposes of federal income tax return. Dow contended that none of the deemed dividend income was derived from…