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

State Throwback and Throwout Rules: "Nowhere" Income, PL 86-272, Tangible and Intangible Sales

$247.00

This course is $0 with these passes:

CPE
ALL
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Description

The varying apportionment formulas in states can lead to disproportional allocations of state income tax. In addition to these, 22 states impose throwback rules, and three have throwout rules. Adding this to the mix often results in even greater distortions of state income tax paid by businesses.

Throwback rules tax sales of tangible property in the state where the sale originated, whether or not the income was earned in this jurisdiction, when the sale is not taxable in the destination state due to lack of nexus. Proponents believe these rules ensure that companies do not avoid taxation on this "nowhere income."

Often overlooked but undoubtedly crucial, the impact of these rules should affect the business location and investment decisions made by companies operating in multiple states.

Listen as our panel of SALT experts discusses the states imposing these rules, how the calculations are made, the interaction of Public Law 86-262 with the throwback rules, and planning opportunities that exist when coordinating sales in multiple jurisdictions.

Presented By

Julia M. Bennetsen
Director, State & Local Tax
Eisner Advisory Group, LLC

Ms. Bennetsen is a Tax Director in the State and Local Tax Group, with nearly 20 years of both public and private accounting experience. She focuses on all aspects of state and local tax, including financial reporting and general consulting. Ms. Bennetsen has significant experience serving clients in the manufacturing, pharmaceutical, technology, and service industries.

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Denisse Moderski
Director
Eisner Advisory Group, LLC

Ms. Moderski is a Director in the firm’s State and Local Tax Group. With over 10 years of experience, she primarily focuses on state and local income taxation and serves clients in a variety of industries, including Financial Services, FinTech, Professional Services, Real Estate, amongst others. Ms. Moderski's specific areas of service include ASC 740, state and local income/franchise tax compliance and consulting matters, including nexus studies, tax due diligence, business entities restructuring, sale of partnership interest analysis, pass-through entity tax elections, state sourcing, state notices resolutions and audit defense.

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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, September 26, 2024

  • schedule

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

  1. Background
    1. Apportionment
    2. Nexus
  2. Throwback rules
  3. Throwout rules
  4. Tangible and intangible property
  5. Interaction with Public Law 86-272
  6. Unitary combined reporting

The panel will review these and other critical issues:

  • What differences are there between state throwback and throwout rules for sales of tangible and intangible property?
  • What recent legislation is shifting the landscape regarding throwback and throwout?
  • How does Public Law 86-272 impact the application of throwback and throwout rules?
  • What are common state apportionment methods and how do these interact with throwback rules?
  • What planning opportunities exist for the distortions presented by application of throwback rules?

Learning Objectives

After completing this course, you will be able to:

  • Ascertain which businesses could be affected significantly by state throwback regulations
  • Determine how to allocate throwback income for business combinations
  • Decide how Public Law 86-272 impacts the application of state throwback rules
  • Identify specific states with throwback and throwout rules
  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

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 .