Speaking Engagement

Apportionment of Services and Intangibles, Section 18

2023 ABA/IPT Advanced Tax Seminars

Royal Sonesta New Orleans
300 Bourbon St
New Orleans, LA

Blank Rome State + Local Tax partner Craig B. Fields will serve as a panelist at the 2023 ABA/IPT Advanced Tax Seminars, hosted by the American Bar Association (“ABA”) Section of Taxation and the Institute for Professionals in Taxation (“IPT”), being held March 13 through 17, 2023.

The program is designed for attorneys, accountants, tax directors, state and local tax managers, government tax officials, appraisers, property tax managers, commercial and industrial property managers, and others interested in sales, use, ad valorem taxation of property, and state income tax.

Craig’s session, “Apportionment of Services and Intangibles, Section 18,” will take place on Monday, March 13, from 9:15 to 10:15 a.m., as part of the State Income Tax Seminar portion of the program.


Apportionment is a common audit issue. Apportionment of revenue from other than tangible personal property, whether cost of performance under the Uniform Division of Income for Tax Purposes Act (“UDITPA”) or a new, and usually less uniform, market sourcing method, requires understanding complex laws and the development of often unclear or unavailable facts. Furthermore, the results often appear less than fair or reasonable, particularly if the taxing authority, because of a lack of records, has presumed an unfavorable result. Then, in such cases, similar complexities regarding the law of alternative apportionment and establishing the best facts become even more important. This panel will recap the pertinent law, address how to develop helpful facts, teach how to present those facts to the auditors, and how to, if necessary, present an alternative apportionment proposal. All of this will be addressed with an eye toward potential litigation.


  • Moderator: Gregg D. Barton, Partner, Perkins Coie LLP
  • Craig B. Fields, Partner, Blank Rome LLP
  • Steven P. Young, Partner, Holland & Hart LLP
  • Kristen Sanocki, Attorney, Thompson Coburn LLP

Other income tax sessions include:

  • Dealing with Tough Audit Issues
  • Business vs. Non-Business Determination/Sourcing
  • SALT Issues Facing Professional Sports Teams and Athletes
  • Current Developments in State Income Taxation of Partnerships and LLCs
  • Credits and Incentives Available for Renewable Energy Projects
  • Current and Hot Topics in SALT M&A
  • Industry Panel—Everything You Need to Know, But Are Afraid to Ask
  • Taxation of Foreign Income/Dividends
  • The Income Tax Nexus Battle: Is Public Law 86-272 Dead or Dying?
  • The Big Easy Brawl
  • Ethics: Continuing Ethical Challenges of Technology as COVID-19 Pandemic Fades (Joint Session with Advanced Sales Tax Seminar)

You can learn more about the State Income Tax Seminar on the IPT website.

Other 2023 ABA/IPT Advanced Tax Seminars:

  • Advanced Sales & Use Tax Seminar (March 14–March 15)
  • Advanced Property Tax Seminar (March 16–March 17)

For additional information and to register, please visit the event webpage.