The Sales Factor Apportionment Method Brings Its Own Challenges - McDermott Will & Emery

The Sales Factor Apportionment Method Brings Its Own Challenges

Overview


Peter Faber wrote this bylined letter to the editor about states’ use of formulary apportionment to determine their shares of a multistate corporation’s income for income tax purposes. Advocating international use of this system as being easier to administer and as a way around expensive disputes about transfer pricing “has its own set of problems that may be as difficult to deal with as the ones that arise under the present system,” Mr. Faber wrote.