A Portion of Apportionment: What’s Your Fair Share?


Stephen Kranz and Diann Smith were among the “seasoned SALT veterans” who discussed state and local tax apportionment in this roundtable interview. Mr. Kranz said that given recent court decisions, “It’s open season on state tax apportionment … If there are no rules for the states, there are no rules for taxpayers; everyone should be looking at what is the position that’s most advantageous to them from a filing perspective.” Ms. Smith agreed, declaring “to the same extent that tax agencies seem to be making up their own rules as to what is considered income that is fairly attributable to the jurisdiction, taxpayers should have that same opportunity.”