Single-Sales Apportionment: Crafting a Multi-State Strategy

Meeting Tax Compliance and Planning Demands Amid Significant Changes in Sales Weighting

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

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Conducted on Thursday, October 6, 2011

Recorded event now available

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This teleconference will provide tax professionals with a thorough briefing on the current status of single-sales or heavier-weighted-sales apportionment throughout the states. The panel will explore the ramifications of each method for businesses and outline effective alternative tax planning strategies.


The ranks of states where corporate taxes focus on sales either exclusively or with the heaviest weight in their income-apportionment formulae continue to swell. With changes like the upcoming California single-sales option and New Jersey three-year phase-in, developments must be constantly monitored.

Meanwhile, Alabama and the District of Columbia recently changed sales weightings to reward home-based companies. Such actions create challenges for taxpayers to keep up with changes and adjust their tax and facilities planning or to source income to a tax-advantaged state.

As a result, companies and their tax staffs must carefully consider the impacts on multi-state tax planning, unitary filing and other key activities. The flexibility, which varies widely, to ask a state for an alternative apportionment approach becomes more critical as apportionment formulae evolve.

Listen as our panel of experienced tax advisors analyzes latest and anticipated developments in the states' trend toward single-sales or heavy sales apportionment, identifies potential consequences for businesses, and outlines tax planning alternative strategies.



  1. The roots of the single-sales apportionment trend
    1. Swing in momentum over last 10 years
    2. Strong majority of states now use single-sales, double-sales or other strong sales weighting
    3. Recent moves by California, New Jersey, Colorado, Utah, Michigan, other states and District of Columbia
  2. Concurrent issues that have an impact
    1. Specialized apportionment formulae for desired industries
    2. Approaches to the unitary group (Finnegan ruling and the group is the taxpayer, Joyce ruling and the members are the taxpayer)
    3. Limitations on the composition of the unitary group
      1. 80/20 rules
      2. Prohibitions against a combination of certain diverse-factor companies
    4. Sourcing of services
      1. Calculation of costs of performance
  3. Resulting planning issues to consider
    1. Unitary filing pros and cons
    2. Alternative apportionment formula requests
    3. Business siting or re-siting decisions


The panel will address these and other key topics:

  • The current situation: Which states now use single-sales apportionment or heavy sales weightings, and which states are heading in that direction.
  • Related issues and trends: Special apportionment formulae for particular industries, unitary group limitations, sourcing of services and costs of performance.
  • Single-sales apportionment: How it can benefit or undermine your company.
  • Planning alternatives: Unitary filings, alternative apportionment formula proposals, siting decisions.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Kirk Lyda
Kirk Lyda

Jones Day

He has more than 10 years of state tax experience in managing audit risk and preparing for field audits, administrative...  |  Read More

Nachbar, Mark
Mark L. Nachbar


Mr. Nachbar specializes in multi-jurisdictional tax services and previously in his tax career was a national managing...  |  Read More

Sarah McGahan
Sarah McGahan

Senior Manager, Washington National Tax

Her job entails tracking state and local judicial and legislative tax developments, briefing clients on proposed and...  |  Read More

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