Apportionment

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.

California’s Move to Single Sales Factor

Beginning January 1, 2011, multistate businesses may elect to use a single sales factor method of apportionment for purposes of their California corporate income tax return.

Income Apportionment and Allocation after Mead

In MeadWestvaco Corp. v. Illinois Dep’t of Revenue, the Supreme Court held that the operational function test was not intended to modify the unitary business principle by adding a new ground for apportionment.

Current Corporate Income Tax Developments (Part II)

During 2009, numerous state statutes were added, deleted, or modified; court cases were decided; regulations were proposed, issued, and modified; and bulletins and rulings were issued, released, and withdrawn. This article covers some of the more important developments in apportionment, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

PRACTICE MANAGEMENT

2019 tax software survey

This annual survey shows how CPAs rate the tax preparation software they used during last tax season and how it handled the recent tax law changes.