Bass, Berry & Sims attorney Mike Sontag provided insight for an article outlining how the lack of uniformity in apportionment had caused a rise in tax gaps. According to Mike, “in view of the demise of uniformity and the difficulty of reaching 100 percent apportionment for taxpayers, UDITPA section 18, which addresses alternative apportionment, is necessary because not all formulas can accurately reflect all business models. However, alternative apportionment should be applied only in truly unusual circumstances and not as a tool for tax administrators — or taxpayers — to undermine legislative choices.”

The full article, “Practitioners Discuss Apportionment, Lament Lack of Uniformity,” was published by Tax Analysts’ State Tax Notes on November 2, 2015 and is available online (subscription required).