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Multistate Income Apportionment

Organize receipts, payroll, property, service-delivery, and nonbusiness income facts used to divide taxable income among states.

5 guided steps Private in your browser Official guidance links

Reviewed June 30, 2026Prepared by Financial Connect, CPAs & Consultants

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Your free guided checker

Answer a few quick questions below. It is private - nothing is submitted or stored - and takes about a minute.

Informational multistate tax screening only; state and local rules vary and must be verified for the applicable year and jurisdiction.

The questions this tool walks you through

Here is what the checker asks and why each step matters. Prefer to talk it through? Contact us and we will help directly.

Do you sell into states beyond your home state - to customers, users, or clients physically located elsewhere?

Apportionment only matters once a second state has jurisdiction to tax part of your income; a purely single-state business divides nothing. Run the test by listing every state where you have customers, users, delivery destinations, employees, or property, not just where you are formed. The common trap is assuming a remote customer base is invisible - post-Wayfair economic nexus can make you taxable in a state you never set foot in.

File in your home state and set a tripwire to re-run this the year you cross a state line; apportionment applies only once income is taxable in more than one state under UDITPA Section 2.

Official guidance: MTC allocation and apportionment resources

Is most of your out-of-state revenue from selling physical goods you ship, rather than services, software, or digital subscriptions?

Goods are sourced to where they are delivered; services and intangibles follow a separate market-versus-cost sourcing fork that changes your answer entirely.

Use the interactive tool above to see how this applies to your situation.

Official guidance: MTC allocation and apportionment resources

In your home state, do you have goods you ship to customers in states where you are not taxable - and does your home state apply a throwback rule?

A throwback rule pulls sales into a state where you have nowhere else taxable to send them; roughly half of states still apply one - confirm your home state's current rule.

Map every no-tax-state shipment and model your home state's throwback (or throwout) exposure before filing, because UDITPA Section 16(b) pulls those nowhere sales back into your home-state numerator. Confirm P.L. 86-272 protection where you only solicit sales of tangible goods, and apply single-sales-factor destination sourcing under UDITPA Section 16(a).

Official guidance: MTC allocation and apportionment resources

For your services or digital revenue, can you identify the state where the customer actually receives or benefits from what you sell?

Market-based states source service receipts to where the customer gets the benefit; if you can pin that down, that is your numerator.

Source service receipts to the customer's benefit location under market-based sourcing, and file where economic-nexus thresholds are crossed per South Dakota v. Wayfair, 585 U.S. 162 (2018).

Official guidance: MTC allocation and apportionment resources

Is the work that generates those service receipts performed mainly from one state - your offices, servers, or staff - rather than spread across the customer's locations?

Cost-of-performance states source service receipts to where you do the income-producing work, not to where the customer sits - the opposite of market sourcing.

Source receipts to your state of performance under UDITPA Section 17 and reconcile it against each market state's conflicting rule to avoid double taxation. Build a defensible reasonable-approximation method and document it before you file inconsistent state numerators, as the MTC market-sourcing regulations require when direct assignment fails.

Official guidance: MTC allocation and apportionment resources

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