Shift Towards Single Sales Factor and Market-Based Sourcing

Recent Changes in Massachusetts, Tennessee, New Jersey, and Vermont

Corey L. Rosenthal, JD, and Shannon Miceli, CPA

The field of state and local taxation is a constantly evolving area. Not only are rules becoming more complex, but the state's ability also to detect irregularities through automation is on the rise. As a result, the calculation of state-sourced income and tax liability is top of mind for many taxpayers. Specifically, the push toward single sales factor and market-based sourcing is an ongoing trend. The increased focus on the sales factor is an area where tax advisors can add immense value to their clients. This article will focus on the shift toward single factor apportionment and market-based sourcing in several key jurisdictions.