Market-Based Sourcing and Multistate Apportionment of Revenue from Services and Intangibles
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax executives and managers with a practical guide to handling challenging state income tax apportionment involving sales of services and intangible personal property. The panel will detail various states' methods of apportioning revenues from services and intangibles, discuss current developments in market-based sourcing, and offer practical guidance on handling multistate apportionment challenges.
- Prior "cost of performance" approaches to sourcing revenue from sales of services and intangibles
- UDITPA Section 18
- Plurality method
- Majority method
- Proportionate method/alternate apportionment
- Market-based sourcing of service revenue methods
- Multistate Tax Compact Model guidance
- Market-based sourcing of revenue from intangibles
- Throw-out rules
- Challenges in apportioning income
- Recent state developments
The panel will discuss these and other relevant topics:
- What are the specific challenges in sourcing revenue from the sale or license of intangible property instead of services?
- What are the main approaches to market-based sourcing implemented by various states?
- What are "throw-out" rules, and when/how do they apply?
- MTC proposed guidance to implement market-based sourcing
- When do states permit or require an alternative apportionment methodology?
Gary C. Bingel, CPA, JD, MBA, CMI
Partner-in-Charge – State & Local Taxes
Mr. Bingel is the Partner-in-Charge of the firm’s State and Local Tax Group. With over 20 years of experience,... | Read More
Mr. Bingel is the Partner-in-Charge of the firm’s State and Local Tax Group. With over 20 years of experience, his expertise focuses on state and local income taxation, and sales and use tax consulting. His practice focuses on income/franchise tax refund reviews; state tax analysis of restructurings; due diligence reviews; sales tax studies; and nexus reviews. In addition, he is experienced in exposure remediation/voluntary disclosure and amnesty agreements; credits and incentives negotiation and analysis; and ruling requests.Close
William T. Pardue
Mr. Pardue specializes in providing state and local corporate income and franchise tax solutions throughout the nation... | Read More
Mr. Pardue specializes in providing state and local corporate income and franchise tax solutions throughout the nation to clients in a variety of industries, including technology, consumer products, manufacturing, hospitality, and financial services companies.Close
Ms. Pascal concentrates her practice in tax law with a focus on New York State, New York City, and multistate tax... | Read More
Ms. Pascal concentrates her practice in tax law with a focus on New York State, New York City, and multistate tax issues. She assists individual and business clients with New York State and New York City audits, including residency, sales tax, unincorporated business tax, commercial rent tax, and corporate tax audits. She also helps clients successfully navigate New York State’s voluntary disclosure process.Close