D Corporation is engaged in the real estate business outside North Carolina and is also partner in the operation of a restaurant in North Carolina. D s interest in the partnership would constitute doing business in this State for income and franchise tax purposes and its share of the partnership net income or loss would be allocated directly to North Carolina. Y Corporation operates a manufacturing business in North Carolina and is a partner in a shopping center venture outside North Carolina. Y s share of the partnership s net income or loss is nonbusiness income allocable outside North Carolina. X, a foreign corporation with manufacturing plants in North Carolina and in several other states, forms an equal partnership with another corporation for the purpose of producing a raw material to be used in its manufacturing process.
X furnishes capital, labor and management for the partnership.
The partnership operation is directly related to and connected with X s regular business, and X s share of the partnership s net income is business income apportionable to North Carolina. Also, the apportionment factors of X should include its proportionate share of the property, payrolls and sales of the partnerships. Z, a foreign corporation with its commercial domicile in New York is engaged in the business of textile manufacturing in North Carolina and other states. It enters into a partnership agreement with an unrelated foreign corporation for the purpose of mineral exploration and provides funds for the venture.