Companies operating in multiple states may apportion and allocate their income for purposes of taxing it, a processes that is intended to divide the income among taxing states like one might divide a pie. While apportionment and allocation can be intimidating, this presentation attempts to make it easier to digest for CPAs working for companies with locations, employees, and sales in multiple states and also for those CPAs advising such client companies.
Learn about the allocation of income.
Learn about the apportionment of income using three-factor apportionment, property,payroll, and sales.
Consider the overlays of the Uniform Division of Income for Tax Purposes Act (UDITPA) and the Commerce Clause of the United States Constitution.
Examine how the apportionment and allocation for example companies are computed.
Mark's areas of practice concentration are state, local and federal tax controversy resolution, litigation and planning. Mark’s practice includes acting as an advocate for clients in resolving disputes with state and local tax authorities (e.g., Kentucky Department of Revenue, Louisville Metro Revenue Commission, etc.) as well as federal administrative agencies including the Internal Revenue Service (IRS), the Alcohol and Tobacco Tax and Trade Bureau (TTB), and the U.S. Department of Agriculture’s Commodity Credit Corporation. He has counseled and advocated for clients with issues involving state and local income, gross receipts, sales and use, property, franchise/license and various excise taxes (e.g., cigarette, other tobacco products, motor fuel, motor vehicle, U-Drive-It, etc.) as well as federal income and excise taxes. Mark also has experience working in industry where he managed the state and local tax and federal excise tax planning and audit defense functions of a multi-billion dollar manufacturing concern.
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