Allocation & Apportionment

State tax considerations around the sale of a partnership interest

This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.

Managing state taxes in an uncertain world

Businesses with employees working remotely in a new location as a result of the pandemic should carefully evaluate the rules in those states to ensure proper withholding.

Illinois Apportionment of Service Income and Unitary Partnerships

Effective for tax years ending on or after Dec. 31, 2008, Illinois enacted a form of market sourcing for sales of services. As part of this change, Illinois excludes a taxpayer’s sales of services from the sales factor when the taxpayer is not subject to tax in the state where the services are received.

Alternative Apportionment: Fairness Is Not the Only Factor

Alternative apportionment provides taxpayers and tax administrators with a means to obtain ad hoc relief when the application of a state’s standard apportionment formula fails to reflect a taxpayer’s business activities in the state.

New Developments in Sourcing Services for Telecommunication Companies

Effective planning and recordkeeping in the apportionment area call for an in-depth understanding of a taxpayer’s business model, including technology-based processes and the related cost accounting systems used, in order to source revenues to the appropriate jurisdiction.

Tax Insider Articles

DEDUCTIONS

Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.