Illinois – Alternative Apportionment Is Authorized

SALT Report 3194– An alternative apportionment is granted to taxpayer.  Taxpayer, ABC Company requested that an alternative apportionment formula be granted and applied to its one time sale of “retail/rental store…that [qualified] for the incidental or occasional sale of assets used in the regular course of business under Regulation Section 100.3380…[which meant] the gross receipts from such a sale…would be excluded from the ABC Company’s sales factor.”   For various reasons noted in the PLR, the taxpayer was approved to apportion the proceeds from their forced sale on an average of the prior 9 years factors resulting in a 4.2251% blended factor as opposed to a 100% allocation.

For Further Information:              

IT 13-0003-PLR 09/18/2013 ALTERNATIVE APPORTIONMENT-PRIVATE LETTER RULING