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Alternative Apportionment: Requesting Relief From Unfair Allocations, Common Alternative Methods, State Nuances

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

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Conducted on Wednesday, November 8, 2023

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This webinar will review the benefits of alternative apportionment for multistate companies struggling with inequitable state tax liability calculations using statutory allocations and apportionment methods. The panelist will explain which companies benefit most from alternative apportionment, review the process for alternative apportionment in specific states, and highlight the most beneficial methods to use in specific scenarios.


Following Wayfair, and with more states moving to single-factor sales apportionment, more businesses are finding relief by utilizing alternative apportionment methods. Statutory formulas for apportioning income often yield disproportionate results for particular companies. These formulas, developed with manufacturers and tangible property sellers in mind, can result in apportion distortion for service-oriented and SaaS companies.

All states offer some type of apportionment relief. The taxpayer requests permission to use an alternative method from the relative tax authority and the burden of proof remains with the taxpayer to show that the statutory methods are distortive and, therefore, unfair. In single-factor apportionment states, taxpayers have successfully argued that the three-factor apportionment method is more determinative in certain situations. Other taxpayers have used transfer pricing studies and separate accounting as acceptable methods to establish more reasonable determinations of state income tax liability. SALT advisers working with multistate businesses must understand the nuances of alternative apportionment to ensure businesses are not burdened with more than their fair share of state income tax.

Listen as George W. Rendziperis, JD, Managing Director, State and Local Tax at M+D Consulting, reviews common scenarios where alternative apportionment can provide a fairer tax allocation and explain how to apply for alternative apportionment in certain states.



  1. Benefits of alternative apportionment
  2. Requesting relief
  3. Alternative methods
  4. State nuances
  5. Common scenarios
  6. Recent rulings


The panelist will cover these and other important issues:

  • The benefits of alternative apportionment for SaaS and service-oriented companies
  • Common alternative methods used in states that use single-factor sales apportionment
  • Applying for an alternative apportionment method in specific states
  • Recent state rulings concerning alternative apportionment


Rendziperis, George
George W. Rendziperis, JD

Managing Director, State and Local Tax
Hancock Askew & Co.

Mr. Rendziperis provides state and local tax advice to companies in the financial services, private equity, real...  |  Read More

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