Advanced Income Tax Apportionment Issues Confronting Multistate Companies

Navigating States' Shift to Market-Based Sourcing, Utilizing Alternative Apportionment and Weighting Factors

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, July 23, 2019

Recorded event now available

or call 1-800-926-7926
Course Materials

This course will prepare tax executives and managers to handle the most complex and challenging apportionment issues with broad application to companies operating in a variety of industries and a large number of states. The panel will go beyond the basics of apportionment for corporate tax professionals who have grasped the fundamentals but need an advanced briefing on resolving complex challenges.


Apportioning income and tax liabilities for companies operating in multiple states presents significant challenges for tax professionals beyond the basics of apportionment. Over recent years many states, and the MTC, now apportion the sale of non-tangible personal property on a market-state basis, rather than on a cost of performance basis.

Many states have deviated from the traditional three-factor apportionment approach to single-factor apportionment. The use of alternative apportionment has increased in recent years. The experiences and guidance of veteran state tax advisers on advanced apportionment issues are invaluable for corporate tax professionals as they approach their companies' compliance and planning.

Listen as our panel addresses the complexities of market-based sourcing, provides a briefing on critical new developments, clarifies the confusing approaches taken by states, outlines essential areas, and offers insights on advanced apportionment challenges.



  1. Analysis for sourcing the receipts from the sale of non-tangible personal property
  2. Issues in dealing with factor weighting
  3. Alternative apportionment issues and strategies


The panel will address these and other important issues:

  • Considerations in apportioning income from the sale of non-tangible personal property in cost-of-performance and market-based states
  • Issues with weighting factors in apportionment formulas
  • The use of alternative apportionment


M.L. Castilla
M.L. Castilla

Ms. Castilla, JD, is a manager in the State and Local Tax Services practice of CohnReznick. She advises clients on...  |  Read More

Pardue, William
William T. Pardue


Mr. Pardue specializes in providing state and local corporate income and franchise tax solutions throughout the nation...  |  Read More

Rabinowitz, Peter
Peter Rabinowitz, JD

Mr. Rabinowitz, JD, is a director in CohnReznick’s Tax Practice. With more than 30 years of experience in tax...  |  Read More

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