Two areas in state income taxation that are not uniformly consistent (and thus bring opportunity and exposure) are the sourcing of service receipts and the categorization of certain types of income as either business or nonbusiness. Retailers need to understand how to source service receipts – whether they are intercompany transactions, bundled transactions, or separate revenue streams in the business. Additionally, today’s difficult economic environment today may lead retailers to sell off certain business units or close down certain operations – which could lead to income that may not be business income.
Grant Thornton is a thought leader in the arena of apportionment of income and has been published in the various articles listed below:
Tennessee offers potential compromise for intangible expense disallowance

