Multistate Income Sourcing: A Shift to Market Based Sourcing and Investee Apportionment
Author: Hodgson Russ LLP, K. Craig Reilly, Emma M. Savino, Brandon J Bourg
| CPE Credit: |
2 hours for CPAs |
This course goes beneath the superficial analytical level to take a deeper look at the evolution of apportionment rules and how they influence tax calculations on an ongoing basis as well as on extraordinary transactions.
As part of this course, state tax attorneys from Hodgson Russ LLP will explore current trends in multistate income sourcing, including national shifts toward single-factor apportionment and customer-based sourcing of service receipts. This course will also examine current hot topics involving income sourcing issues such as “investee apportionment” and how best to address situations in which a portion of a particular item of income might be sourced to multiple jurisdictions resulting in double taxation.
Publication Date: March 2026
Designed For
All CPAs, enrolled agents, tax return preparers, tax attorneys, corporate attorneys, and other practitioners who review or are responsible for preparing multistate tax returns for clients or advise on multistate tax issues will benefit from this insightful webinar.
Topics Covered
- The Evolution of Single-Factor Apportionment
- Customer-Based Sourcing for Businesses
- How States Address Problem Situations Involving Multiple Points of Use and Transient Delivery Locations
- Jurisdictions that Depart from Single-Factor Customer-Based Sourcing for Business Taxation
- Personal Income Tax Sourcing Issues for Non-Business Income Sourcing (e.g. Investee Apportionment)
Learning Objectives
- Identify circumstances in which business tax apportionment rules may differ from individual tax apportionment rules permitting for planning opportunities
- Understand how apportionment affects the amount of tax paid in a particular jurisdiction
- Identify transactional situations that may become problematic as apportionment rules evolve
- Identify situations in which a portion of a particular item of income might be sourced to multiple jurisdictions resulting in double taxation
- State the concept of “Investee Apportionment” and how it may affect the structuring of transactions
- Identify the different income sourcing rules that might apply to different income streams
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
