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Tax Advisory & Compliance
Participants will identify procedural do’s and don’ts, state-to-state variations with letter rulings and alternative apportionment petitions, and how expert reports may support these requests.
Host: Samir Ramakrishna, senior manager, Deloitte Tax LLP
Presenters: Joe Garrett, managing director, Deloitte Tax LLP
Austin Riopelle, senior manager, Deloitte Tax LLP
Philip Trampe, partner, Deloitte Tax LLP
1.0 Overview CPE credit | Taxes
Key takeaways
The move to market-based sourcing and single sales factor apportionment, combined with evolving business models, has increased the complexity of state tax calculations. Taxpayers now face challenges in characterizing revenues and complying with varying state requirements, often leading to apportionment results that do not fairly reflect in-state business activity. We’ll discuss:
- Proactive measures to seek relief from inequitable apportionment and treatment of unusual transactions
- Common challenges in revenue characterization (e.g., services, intangibles)
- When alternative apportionment methodology may be warranted
