How is the credit apportioned?
The credit is apportioned to Michigan “by a fraction, the numerator of which is the total activity of the private equity fund manager conducted in this state during the tax year and the denominator of which is the total activity of the private equity fund manager conducted everywhere during the tax year.” MCL 208.1453. The “total activity of the private equity fund manager” is measured by the receipts of the private equity fund acting as an “eligible taxpayer,” and includes the sale of investment assets and investment related receipts. “[T]he location of the activity of the private equity fund manager is based on the location of the office from which the fund manager conducts management activity for the eligible taxpayer.” MCL 208.1453. Thus, the apportionment formula is the receipts of the private equity fund derived from investments managed by the fund manager from offices in Michigan over receipts derived from investments managed by the fund manager everywhere. For example, a privat
