Apportionment Issues

Schadewald, Michael
May 2006
Journal of State Taxation;May/Jun2006, Vol. 24 Issue 4, p9
Academic Journal
The article discusses the cost-of-performance rule of the Uniform Division of Income for Tax Purposes Act (UDITPA) in the U.S. It is stated that under the Section 17 of UDITPA that gross receipts from sales other than sales of tangible personal property are attributed to the state in which the income-producing activity is performed. The taxpayer must first determine what activity produced the income to source sales of services under the UDITPA income-producing activity rule. Meanwhile, several states that employ the income-producing activity rule to source sales of services conform to the approach espoused by Multistate Tax Commission Reg. IV.17 of excluding payments to independent contractors from the costs-of-performance analysis.


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