484 LAWS OF MARYLAND. [CH. 277

allowable deductions, respectively, that proportion of the in-
vestment income, ordinary income and allowable deductions,
respectively, of the partnership for the annual accounting
period of the partnership ending with or in the taxable year
of the partner, that such partner's distributive share (whether
distributed or not) of the net income of the partnership for
such annual accounting period, bears to the total net income
of the partnership for such annual accounting period.

246. Allocation of Corporate Income. The net income
of a corporation (domestic or foreign) shall be allocated in the
following manner:

(a) Income from ground rents, rents and royalties and
other income from real estate or tangible personal property
permanently located in this State (less related expenses) shall
be allocated to this State; and such income from real estate or
tangible personal property permanently located outside this
State (less related expenses), shall be allocated outside this
State.

(b) The remaining net income (including net income from
dividends and interest on intangible personal property having
a business or commercial situs either in this State or outside
this State but excluding net income from dividends and in-
terest on other intangible personal property), hereinafter re-
ferred to as business income, shall be allocated to this State
if the trade or business of the corporation is carried on wholly
within this State, but if the trade or business of the corpora-
tion is carried on partly within and partly without this State,
so much of the business income of the corporation as is derived
from or reasonably attributable to the trade or business of the
corporation carried on within this State, shall be allocated to
this State and any balance of the business income shall be allo-
cated outside this State. The portion of the business income
derived from or reasonably attributable to the trade or busi-
ness carried on within this State shall be determined by sepa-
rate accounting where practicable, but where separate account-
ing is not practicable, the portion of the business income of the
corporation allocable to this State shall be determined in such
manner as may be prescribed by rules and regulations of the
Comptroller. The Comptroller is hereby authorized to pre-
scribe by rules and regulations such method or methods of
allocating the business income of corporations as may justly
and fairly determine the portion thereof derived from or rea-
sonably attributable to the trade or business carried on within
this State.

247. Tax a Personal Debt. Every tax imposed by this sub-
title, and all increases, interest and penalties thereon, shall