State Corporate Income Apportionment: Key Fundamentals and Legislative Trends

Understanding State Approaches to Factor Weighting, Service Revenue, Key Apportionment Concepts

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

Conducted on Thursday, August 9, 2018

Recorded event now available

or call 1-800-926-7926
Program Materials

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


Tax professionals, primarily 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 differentiate states’ approaches to income apportionment, market-based and cost-of-performance sourcing, and definitions of throwback and throwout.

Tax reform, regulations, and court rulings are reshaping the apportionment landscape. An explanation of essential multistate 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 thorough overview of the essential concepts in state apportionment of business income for taxation.



  1. Apportionment formulae key concepts
    1. Sales, payroll and property factors
    2. Single-sales apportionment
  2. How market-based and cost-of-performance sourcing work
    1. Sourcing of sales involving common carrier delivery
  3. Examples of throwback and throwout rules
  4. Latest developments stemming from tax reform, state courts and legislatures
    1. Recent cases and impact on multistate tax compact
    2. Latest 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 impact of tax reform and considerations for apportionment methods
  • States that employ throwback and throwout provision—and what they mean for corporate taxpayers


Michael J. Cataldo
Michael J. Cataldo

Special Counsel
Pillsbury Winthrop Shaw Pittman

Mr. Cataldo represents corporate and individual clients in state and local tax controversies across the country during...  |  Read More

Reed, Jeffrey
Jeffrey S. Reed

Kilpatrick Townsend & Stockton

Mr. Reed is the Chair of the State and Local Tax Practice. He represents businesses and individuals in state tax...  |  Read More

Shaikh, Mike
Mike Shaikh

Reed Smith

Mr. Shaikh represents corporate clients on state tax controversy matters and specifically works with them on...  |  Read More

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