Understanding The Apportionment Rules For Service-Based Businesses

Webinar: ID# 1014012
Recorded CD
About This Course:
Apportionment of income for state tax purposes is where the rubber meets the road. That is to say, the complex and varied rules for determining a taxpayer's state income tax apportionment percentage can provide opportunities, with careful planning, for state tax minimization or create traps, without such planning, that lead to multiple taxation.

Service-based businesses face particular difficulties in identifying and analyzing the rules applicable to their operations for two reasons. First, state apportionment rules were written several decades ago, at a time when our economy was dominated by the manufacturing of tangible personal property. Thus, these rules focused on the manufacturing industry and were out of touch with service operations. Second, as our economy has shifted its focus to services and e-commerce, states are beginning to revise their apportionment rules to account for differences between the industries. These new rules lack clear guidance thus creating uncertainty for taxpayers.

This live webinar will provide a comprehensive look at particular apportionment issues facing service-based business in order to arm you with the information necessary to structure your operations to take advantage of the opportunities and avoid the traps.

  • Basic Apportionment Concepts
    • What Is Apportionment?
    • Constitutional Limitations
    • Trends in Apportionment
  • Rules for Sourcing Service Receipts
    • Income Producing Activity Method
    • Market-Based Sourcing Method
    • Industry Specific, Hybrid and Other Methods
  • Special Apportionment Issues
    • Service vs. Tangible Personal Property vs. Intangible Property
    • Bundling
    • Personal Service Receipts
    • Unitary Combined Reporting Considerations
    • Economic Substance and Related Tax Doctrines
    • Non-Income-Based Taxes – Franchise, Gross Receipts, etc.

Jeffrey C. Glickman J.D., LL.M.
  • Partner-in-Charge of the State and Local Tax Practice at Habif, Arogeti & Wynne, LLP, an independent CPA firm in Atlanta
  • Practice focuses on multistate tax planning and business transactions
  • Experience in structuring business transactions, and developing and implementing new business structures in a manner designed to minimize state and local tax liabilities
  • Maintains a multistate administrative tax dispute and negotiation practice, including obtaining letter rulings, preparing and negotiating amnesty applications, and assisting clients during audits
  • Adjunct professor at Emory Law School, where he teaches a class in multistate taxation
  • Recognized as a Georgia Super Lawyers Rising Star for 2005 to 2007 as featured in Atlanta Magazine
  • Frequent lecturer for the Committee on State Taxation, the Institute for Professionals in Taxation, the Interstate Tax Corporation, Lorman Education Services, the Institute for Continuing Legal Education, and the Tax Executives Institute
  • J.D. degree and LL.M. degree in taxation, New York University School of Law; B.S. degree, Cornell University
Understanding The Apportionment Rules For Service-Based Businesses
Available on CD format
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