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March 18, 2013
ABA/IPT Advanced Income Tax Conference
On March 18 and 19, Sutherland Of Counsel Prentiss Willson will participate in a panel discussion regarding current projects and proposals before the MTC. The primary focus will be on the proposed revisions to UDIPTA, including the proposals to replace cost-of-performance principles with market-based sourcing rules; to replace the equally weighted three-factor apportionment formula with a double weighted sales factor; to expand the definition of business income; to narrow the definition of gross receipts; and to expand the authority under section 18 to use alternative apportionment formulas.
In addition, the panel will examine a proposed statute that would impose on the income of pass-through entities that are more than 50 percent owned by an entity not subject to income tax; the proposed associate nexus concept that has expanded into representational nexus generally; and the controversial proposal to begin a project to expand the use of section 482.
Finally, the panelists will comment on the overall impact that the MTC has had on industry, including the extent to which it has achieved its mission of promoting uniformity.
To visit the conference website, click here.