State Corporate Income Apportionment: Key Fundamentals and Legislative Trends
Understanding State Approaches to Factor Weighting, Service Revenue, Key Apportionment Concepts
Recording of a 110-minute CPE webinar with Q&A
This course will provide SALT practitioners working with multistate companies a review of key apportionment concepts, relevant court decisions, and new state laws and proposals.
Outline
- Apportionment formulae key concepts
- Sales, payroll, and property factors
- Single-sales apportionment
- How market-based and cost-of-performance sourcing work
- Sourcing of sales of services
- Examples of throwback and throwout rules
- Apportionment issues for Sales of a Business
- Apportionment issues for Partnerships and Pass-through Entities
- Alternative apportionment
- Combined reporting apportionment issues
- Latest developments stemming from tax reform, state courts, and legislatures
- Recent legislative and judicial developments
Benefits
The panel will review these and other important topics:
- Apportionment formulae and the latest snapshot of single-sales states
- Cost-of-performance and market-based sourcing rules
- The impact of tax reform and considerations for apportionment methods
- States that employ throwback and throwout provisions--and what they mean for corporate taxpayers
Faculty
Jeffrey S. Reed
Partner
Kilpatrick Townsend & Stockton
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals... | Read More
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the U.S. He brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. He is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.
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Mike Shaikh
Partner
Baker McKenzie
Mr. Shaikh practices exclusively in state and local tax on California and multistate tax controversy and planning. He... | Read More
Mr. Shaikh practices exclusively in state and local tax on California and multistate tax controversy and planning. He handles matters at administrative audit and appeal levels and judicial proceedings on matters involving corporate and personal income tax, tax on trusts, sales and use tax, property tax, payroll tax, local business license taxes, and other taxes administered by state and local governments. He also provides tax advice on return positions, reorganizations, mergers and acquisitions, and other transactions. He is experienced in handling just about any issues related to state and local taxation.
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