An Overview of the Sales Apportionment Factor and its Application to Sales of Financial Instruments

Garst, Michael A.
March 2008
Journal of State Taxation;Mar2008, Vol. 26 Issue 3, p15
Academic Journal
The article discusses the concept of sales apportionment factor as well as its application to the sales of financial instruments in the U.S. It states that it has become a trend among U.S. states to shift their three factor apportionment formula towards a single sales apportionment factor in accordance to their state income tax policies. It provides an overview on the sales apportionment factor, its methodologies as well as its sales factor treatment regarding the receipts of the sales of intangible assets. It also cites the implications of the Court's decision about the case of Microsoft Corp.


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