Apportionment Issues

Schadewald, Michael S.
November 2011
Journal of State Taxation;Nov/Dec2011, Vol. 30 Issue 1, p5
Academic Journal
The article offers an interpretation of Section 16 of the Uniform Division of Income for Tax Purpose Act (UDITPA) regarding the proper application of destination test to dock sales. It states that Section 16 provides implications for sales of tangible personal property that are to be sourced to a state either by delivery of shipment to a purchaser. Moreover, a dock sale has been consistently ruled by state courts to be assigned to state where the purchaser is located.


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