State Corporate Income Apportionment: Key Fundamentals and Legislative Trends

Understanding State Approaches to Factor Weighting, Service Revenue, Joyce v. Finnegan, Gillette and Other Apportionment Concepts

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

Conducted on Tuesday, May 30, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar will prepare tax staff for state income tax compliance by multi-state companies with a review of key apportionment concepts, relevant court decisions, and new state laws and proposals.


Tax professionals, particularly those new to state corporate income tax compliance, require a sturdy grounding in the similarities, differences and latest trends in state approaches and formulae for apportioning a company’s income.

Grasping the role of sales, payroll and property factors and developing an awareness of the single-sales formulae are a strong start. Tax pros must also learn the differences between Joyce and Finnigan approaches to income apportionment, market-based and cost-of-performance sourcing, and definitions of carryback and throwout.

Gillette Co. v. Franchise Tax Bd. (the Supreme Court denied cert. Oct. 11, 2016, leaving the California Supreme Court’s ruling intact), other recent state court rulings, and state legislation are reshaping the apportionment landscape. An explanation of essential multi-state concepts governing apportionment of income will position newer tax specialists at companies and accounting firms to work more effectively.

Listen as our panel of experienced tax advisers provides a fundamental overview of the most essential concepts in state apportionment of business income for taxation.



  1. Apportionment formulae key concepts
    1. Sales, payroll and property factors
    2. Trend to single-sales apportionment
  2. How market-based and cost-of-performance sourcing work
    1. Sourcing of sales involving common carrier delivery
  3. Examples of carryback and throwout rules
  4. Latest developments in state courts and legislatures
    1. Gillette and other cases, impact on multi-state tax compact
    2. Recent legislative and judicial developments


The panel will explain these and other important topics:

  • Factor-weighting in apportionment formulae, and the latest snapshot of single-sales states
  • Cost-of-performance and market-based sourcing rules
  • The practical differences between a Joyce and Finnigan state
  • States that employ carryback and throwout provision—and what they mean for corporate taxpayers


Barry H. Horowitz, CPA, MST
Barry H. Horowitz, CPA, MST


Mr. Horowitz has over 30 years of professional accounting experience and is the Team Leader of the...  |  Read More

Akash Sehgal
Akash Sehgal

Green Hasson Janks

Mr. Sehgal leads the Firm’s state and local tax practice with a focus on multistate income and franchise tax,...  |  Read More

Stephen Basiaga, JD, LLM
Stephen Basiaga, JD, LLM


Mr. Basiaga works within the Firm's State and Local Tax, Tax Controversy and National Tax Services' Groups,...  |  Read More

Frances Ellington
Frances Ellington
Tax Manager
Green Hasson Janks

Ms. Ellington has experience in state tax controversy, multi-state planning and multi-state compliance in both public...  |  Read More

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