Institute for Professionals in Taxation 42nd Annual Conference
JW Marriott & the Douglas Hotels at Parq Vancouver
Vancouver, British Columbia
Litigation relating to alternative apportionment has steadily increased in recent years. As states grapple with the explosion of the service and intangibles based economy, they have begun to require various industries and individuals to source receipts in manners that deviate from the controlling statutory formulas. Meanwhile, states often apply a much higher burden of proof when taxpayers request alternative apportionment themselves.
This session will examine the states' different approaches to alternative apportionment, both in terms of the mechanics of obtaining or requiring alternative apportionment as well as the specific situations in which states have required or denied such apportionment.