Interested in training for your team? Click here to learn more

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

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, March 26, 2020

Recorded event now available

or call 1-800-926-7926

This course will provide SALT practitioners working with multistate companies a review of key apportionment concepts, relevant court decisions, and new state laws and proposals.


State tax sourcing and apportionment issues are growing in importance as many companies now have nexus with new states under state economic nexus laws. Avoiding sourcing the same receipt to multiple states is crucial to keeping state taxes manageable.

Tax professionals should have a basic understanding of how state tax apportionment rules work and should know the major differences between state approaches.

For those with a solid understanding of the basics, it is helpful to remain informed about new developments, including legislative and regulatory changes, and case law that impacts how current laws and regulations are applied.

Listen as our panel of experienced tax attorneys provides a summary of the essential concepts impacting state income tax apportionment and also identifies key trends and recent developments that tax professionals should know.



  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 of services
  3. Examples of throwback and throwout rules
  4. Apportionment issues for Sales of a Business
  5. Apportionment issues for Partnerships and Pass-through Entities
  6. Alternative apportionment
  7. Combined reporting apportionment issues
  8. Latest developments stemming from tax reform, state courts, and legislatures
    1. Recent legislative and judicial developments


The panel will review these and other important topics:

  • 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 provisions--and what they mean for corporate taxpayers


Reed, Jeffrey
Jeffrey S. Reed

Kilpatrick Townsend & Stockton

Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals...  |  Read More

Shaikh, Mike
Mike Shaikh

Baker McKenzie

Mr. Shaikh practices exclusively in state and local tax on California and multistate tax controversy and planning. He...  |  Read More

Access Anytime, Anywhere

CPE credit is not available on downloads.