Sales Factor: Destination Sales, Dock Sales, Throwback and Throw-Out
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Take the guesswork out of the various sales assignment rules and proper state income tax apportionment.
Taxpayers doing business in multiple jurisdictions have to deal with various sales assignment rules that can be challenging to experienced tax experts. This topic will assist you in understanding how to assign sales, when to throwback sales, supporting the decision to no throwback sales and when the throw-out rule applies. This matter is frequently the focus of tax examinations and can result in unplanned tax assessments. Having an understanding of these rules assists taxpayers in properly computing apportionment formulas and provides a foundation for future planning.
AuthorsPaul McGovern, CPA, BDO USA, LLP
Purpose of the Sales Factor
• Assignment of Sales
• Tangible Goods vs. Services
• Ultimate Destination of the Purchaser
• Mobile Property
• How to Identify?
• When Do Dock Sales Become an Issue?
• Can the Sale Be Counted by Two States?
• Taxable in Another State
• What Is a Throwback Sale?
• When to Throwback to Your State?
• Joyce v. Finnigan Rules
• Burden of Proof
• Foreign Sales
• Double Throwback
• When Does It Apply
• Recent Developments