Multistate Income Sourcing: Performance Based vs. Market Based Sourcing
States use a variety of methods to source the income or profits from multijurisdictional businesses. This program from the corporate tax experts at Hodgson Russ LLP will discuss sourcing issues and methods, including cost of performance and market-based sourcing. Recent developments, including new market-based sourcing regulations and key cases involving what constitutes an income-producing activity, will be reviewed to help companies and professionals properly characterize business activities for purposes of apportionment, understand complex hierarchal rules for sourcing receipts from digital products or services, as well as when to consider a request for alternative apportionment.
Topics Covered
- Formula apportionment and single factor apportionment
- Sourcing receipts from sales of tangible personal property and digital products
- Sourcing service receipts: cost of performance vs. market-based sourcing
- Special apportionment rules for certain industries
- Equitable apportionment/Alternative apportionment
- Treatment of apportionment formulas in combined and consolidated returns
Learning Objectives
- Understand how to characterize business activities for purposes of apportionment
- Navigate the nuances of cost of performance and market-based sourcing
- Identify alternative apportionment considerations
- Recognize key audit issues and understand steps to address such issues at the tax return filing stage
Level
Overview
Instructional Method
Group: Internet-based
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
