Apportionment/Revenue Sourcing Studies

From an income/franchise tax standpoint, properly apportioning your revenue amongst the various states where you have nexus is crucial to neither overpaying nor underpaying your taxes.

Unfortunately, states’ apportionment provisions are exceedingly complex and nuanced.  Apportionment provisions vary not just between the states, but often between types of entities, as well as types of business.  Also, concepts such as throw-back and throw-out are often overlooked and can have a material impact on your tax calculations.  Even seemingly simple concepts such as market-sourcing can be a maze of complexity and nuance.

We can review your apportionment calculations to help you properly comply with the applicable sourcing provisions.  This includes analyzing whether you should be using a costs of performance method for sourcing receipts from services (and if so, which type of costs of performance method), as well as helping to identify your market and where it is located.  Our goal is to minimize both your tax liabilities and your exposure, while remaining fully compliant with the tax laws.