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
Instructors
Hodgson Russ LLP
Hodgson Russ has approximately 200 attorneys in offices in Albany, Buffalo, New York City, Rochester and Saratoga Springs, New York; Hackensack, New Jersey; Palm Beach, Florida, and Toronto, Canada.
We serve a wide range of clients, from multinational and privately held corporations to nonprofit organizations, governmental entities, and individuals. Our attorneys practice in every major area of law and use multidisciplinary work teams to serve the specific, often complex, needs of our clients.
K. Craig Reilly
Craig is a partner in the firm’s State & Local Tax Practice. Craig counsels businesses and individuals in a range of state and local tax issues, with a focus on New York State, New York City, New Jersey, and multistate tax issues.
Prior to joining Hodgson Russ, Craig was a judicial intern for the Honorable Jane A. Resanti of the U.S. Court of International Trade and an investigative analyst at the New York County District Attorney's Office.
Craig advises clients on all aspects of state and local tax from planning and compliance to controversy and litigation. He represents clients in disputes with the New York State Department of Taxation and Finance, New York City Department of Finance, and New Jersey Division of Taxation and is experienced in handling sales tax, corporate franchise tax, personal income tax, and residency audits.
Craig works closely with remote retailers and cloud-based software vendors on a variety of multistate tax compliance issues, including filing requirements, sales and use tax collection obligations, income allocation and apportionment, tax registrations, and applications for voluntary disclosure and other amnesty programs.
Emma M. Savino
Emma Savino is an associate in the State and Local Tax Practice. She handles disputes involving the New York State and City Tax Departments and counsels businesses and individuals in a range of multistate, state and local tax issues. She advises clients on all aspects of state and local tax from planning and compliance, to audit and litigation.
Prior to joining Hodgson Russ, Emma served as a volunteer law clerk for United States District Judge William Skretny of the Western District of New York. She was also employed as a law clerk at a local firm for nearly two years. Prior to attending law school, Emma worked for TJX Canada as an allocation analyst.
Brandon J Bourg
Brandon is a member of the firm’s State & Local Tax Practice. He counsels individual and business clients on all aspects of state and local tax, including planning, compliance, audit, and litigation.
During law school, Brandon served as a student practitioner in the Syracuse University College of Law Transactional Law Clinic. Brandon was a member of the Travis H.D. Lewin Advocacy Honor Society Negotiation Team and an Executive Editor of the Syracuse Law Review.