State scrutiny over sourcing income to individual jurisdictions has never been higher, particularly on taxpayers in the service industry. TaxOps’ Meredith Smith and Fredrikson & Byron’s Masha Yevzelman discuss sales factor market sourcing concepts and court cases at the IPT 47th Annual Conference June 25-28 in Grapevine, Texas, moderated by TaxOps’ Stacey Roberts.

Always Forward Marching – Sourcing Rules for Income Tax Planning

June 27, 2023 | 2:30 – 3:30 pm CT

Institute for Professionals in Taxation 47th Annual Conference

With increased scrutiny from states, the pressure on taxpayers to understand and comply with ever-changing rules on sourcing income to individual jurisdictions has never been higher, particularly on taxpayers in the service industry. TaxOps’ Meredith Smith and Fredrikson & Byron’s Masha Yevzelman discuss in this session the evolution of the sales factor market sourcing concepts. The speakers will also address some of the new cases arising in this area to ensure practitioners understand how to use these decisions to proactively apply them as state tax apportionment mitigation strategies. Moderated by TaxOps’ Stacey Roberts at the IPT 47th Annual Conference June 25-28 in Grapevine, Texas.

Benefits

After attending the session, the attendee will be able to:

  1. Describe the various methodologies states apply to determine the “market” for sales other than tangible personal property
  2. Identify who the customer is for sourcing purposes
  3. Compare challenges of market sourcing vs. cost of performance sourcing
  4. Identify trends in state adoption of sourcing methodologies and economic or factor-presence nexus standards
  5. Discuss challenges with sourcing for certain industries and throwout.

Presented By

Meredith Smith, CPA
Partner, TaxOps

Masha Yevzelman, Esq.
Attorney, Fredrikson & Byron, P.A.

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