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Advanced Income Tax Apportionment Issues Confronting Multistate Companies

Navigating States' Application of Market-Based Sourcing, Utilizing Alternative Apportionment, and Weighting Factors

Note: CLE credit is not offered on this program

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

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Conducted on Thursday, October 5, 2023

Recorded event now available

or call 1-800-926-7926

This course will prepare tax executives and managers to handle the most complex and challenging apportionment issues with broad application to companies operating in various 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 rather than on a cost-of-performance basis.

Many states have moved 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. Advanced income tax apportionment issues: introduction
  2. Sourcing of receipts from service and intangibles
  3. Alternative apportionment
  4. Throwback and throwout rules
  5. Joyce and Finnigan rules
  6. Pass-through entity issues


The panel will address these and other vital 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
  • Advanced apportionment issues for corporations


Bennetsen, Julia
Julia M. Bennetsen

Director, State & Local Tax
Eisner Advisory Group

Ms. Bennetsen is a Tax Director in the State and Local Tax Group, with nearly 20 years of both public and private...  |  Read More

Dobson, Duane
Duane Dobson

Director, State Income/Franchise Tax Consulting

Mr Dobson provides useful assistance when addressing state and local tax matters, including advice regarding direct,...  |  Read More

Feehan, Joseph
Joseph R. Feehan, LL.M., J.D.


Mr. Feehan is a State and Local Tax partner in the Firm’s Boston Office. He works with a diverse group of Marcum...  |  Read More

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