BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Corporate Tax
  • schedule 110 minutes

Market-Based Sourcing and Multistate Apportionment of Revenue From Services and Intangibles

$247.00

This course is $0 with these passes:

CPE
ALL
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Description

To date, about two-thirds of the states have moved to apportion the sale of non-tangible personal property on a market-based approach basis rather than on a cost of performance basis. This trend has coincided with states' deviation from a traditional three-factor apportionment approach to a single-factor apportionment.

Market-based sourcing requires sellers to apportion income from the sales of services to the state where services are received by or delivered to the purchaser or where the benefit of the services is received. While one rationale for moving to a market-based apportionment is administrative ease, determining where a service or intangible is delivered or where such benefit is received presents numerous challenges to corporate tax professionals. This is especially true when the location where the buyer receives the benefit is indeterminable.

Listen as our experienced panel provides practical guidance and the most recent developments to state initiatives to implement market-based sourcing of income arising from sales of services or intangible personal property.

Presented By

George W. Rendziperis
Director
Baker Tilly

Mr. Rendziperis provides state and local tax advice to companies in the financial services, private equity, real estate, technology, manufacturing, oil and gas, and service sectors. He has more than 15 years of experience advising clients on controversy, litigation, planning, implementation and compliance issues related to income and franchise tax, sales and use tax, excise and property taxes, unclaimed property, and tax incentives and credits.

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Penny Sweeting
State and Local Tax, Senior Manager
Withum

Ms. Sweeting is a Senior Manager, State and Local Tax at Withum. 

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

Date + Time

  • event

    Thursday, April 17, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Prior "cost of performance" approaches to sourcing revenue from sales of services and intangibles
    1. UDITPA Section 18
    2. Plurality method
    3. Majority method
    4. Proportionate method/alternate apportionment
  2. Market-based sourcing of service revenue methods
  3. Multistate Tax Compact Model guidance
  4. Market-based sourcing of revenue from intangibles
  5. Throw-out rules
  6. Challenges in apportioning income
  7. Recent state developments

The panel will discuss these and other relevant topics:

  • What are the specific challenges in sourcing revenue from the sale or license of intangible property instead of services?
  • What are the main approaches to market-based sourcing implemented by various states?
  • What are "throw-out" rules, and when/how do they apply?
  • MTC proposed guidance to implement market-based sourcing
  • When do states permit or require an alternative apportionment methodology?

Learning Objectives

After completing this course, you will be able to:

  • Identify different market-based sourcing methods for income from sales of services
  • Recognize how various states apply market-based sourcing
  • Determine the impact of the Multistate Tax Compact model on states' approaches to market-based sourcing
  • Discern possible traps in apportioning income among different market-based rules
  • Establish the states' various approaches to "throw-out" rules and alternative apportionment
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, dealing with complex multi-state sales and use tax collecting and reporting; supervisory authority over other preparers/accountants. Specific knowledge of basic apportionment methods, understanding of differences between tangible and intangible property for state income tax purposes; familiarity with cost of performance methodologies and single-factor apportionment rules.

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .