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Understanding the Apportionment Rules for Service-Based Businesses


Gain a better understanding on the importance of proper revenue sourcing and the special apportionment rules for service-based businesses.

The sourcing rules adopted by the various states are far from uniform, and states have been challenged to keep pace with the exponential growth of service-oriented enterprises, especially in the technology sector. This topic will discuss the various sourcing rules currently adopted by states and practical application to several common industries, including personal and professional services, technology, including cloud-computing enterprises such as Software-as-a-Service, and how to source revenues from the licensing or use of intangibles. We will also address some unique situations and what types of contemporaneous documentation are helpful in an audit.

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Understanding the Apportionment Rules for Service-Based Businesses


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Understanding the Apportionment Rules for Service-Based Businesses


Elil Shunmugavel Arasu

Elil Shunmugavel Arasu


  • Managing Director in the McLean, Virginia office of BDO USA, LLP
  • More than 15 years of state tax consulting experience and consults on all aspects of state income tax, including participating in mergers and acquisition transactions, due diligence reviews, representation on state tax controversy matters, and assisting companies with state tax compliance and ASC 740
  • A regular speaker on state and local topics in Washington, D.C., Virginia and Maryland
  • Member of the Virginia State Bar
  • LL. M. degree, Georgetown University Law Center; J.D. degree, University of California, Hasting College of the Law; B.A. degree in political economy, University of California, Berkeley
  • Can be contacted at 703-336-1652 or [email protected]
Christian J. Burgos, Esq.

Christian J. Burgos, Esq.

Friedman LLP

  • State and Local Tax (SALT) Managing Director in BDO USA, LLP's Orange County office
  • A State and Local Tax professional with over 13 years of experience advising business and individual clients in multistate tax matters, which include, but are not limited to, multistate income/franchise and sales and use tax compliance, nexus analyses, apportionment studies, state tax provisions, restructurings and mergers and acquisitions
  • Has extensive experience representing business and individual clients before multistate taxing authorities in tax examinations and administrative appeals processes
  • Has also advised clients on broad array of federal and state credit and incentives opportunities, with a primary focus on California state credits
  • Presently sits as an adjunct faculty member with California State University, Fullerton, where he teaches state and local taxation as part of the University's Master of Science in Taxation (MST) program
  • Written several articles on topics on state corporate income and franchise taxation for trade periodicals, such as the AICPA's The Tax Advisor
  • Memberships include The State Bar of California (Lic. No. 250741); United States Tax Court (Lic. No. 0725); and member of the Institute of Professionals in Taxation (IPT)
  • J.D. and LL.M. degrees in taxation, Loyola Law School, Los Angeles; B.A. degree in political science, University of California, Los Angeles
  • Can be contacted at 714-668-7356 or [email protected]
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Understanding the Apportionment Rules for Service-Based Businesses

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