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State Corporate Income/Franchise Tax Cost-of-Performance Apportionment: How Similar Statutes can Yield Very Different Results

Deloitte Dbriefs | Multistate Tax

Start Date and Time

May 7, 2013 2:00 PM

End date and time

May 7, 2013 3:00 PM

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(GMT-05:00) Eastern Time (US & Canada)

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Host: Karen Boucher, Director - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes 

For state income and franchise tax purposes, many states have employed cost-of-performance standards for apportioning receipts from sales of intangible property and services. But what if two states with similar statutes reach different conclusions? We'll discuss:

  • How states typically approach cost-of-performance standards.
  • Conclusions of tax authorities and courts in Massachusetts and Oregon regarding the application of their respective standards.
  • What to look for in cost-of-performance statutes and related rules, including important definitions, to discern how the standards operate.

Learn how state treatment of cost-of-performance standards could impact how you apportion receipts from sales of intangible property and services.

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