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Course Details

Understanding the Apportionment Rules for Service-Based Businesses

Webinar: ID# 1011719
Recorded CD
Qty:
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 audio conference 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.

Agenda

    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
    • Economic Substance and Related Tax Doctrines
    • Nonincome-Based Taxes – Franchise, Gross Receipts, Etc.
    Faculty

    Jeffrey C. Glickman, Esq.

    • Counsel in the State and Local Tax Group with the law firm of Alston & Bird LLP's Atlanta office
    • 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 achieve multistate tax efficiencies
    • 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 multistate taxation class
    • 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
    • Wrote, co-wrote or contributed to articles appearing in various national tax publications
    • J.D. degree and LL.M. degree in taxation, New York University School of Law; B.S. degree, Cornell University
    • bio info

    Who Should Attend

    accountants, CPAs, controllers, CFOs, tax managers, tax preparers, finance directors, presidents, vice presidents, accounts payable professionals, bookkeepers, enrolled agents and attorneys.

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