Special industry apportionment rules – refresh or fade away?

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Special industry apportionment rules – refresh or fade away?

June 29, 2026

United States
United States
United States
In this installment of “A Pinch of SALT,” published by Tax Notes State, Partners Michele Borens and Jeremy Gove examine the evolving role of special industry apportionment rules and the Multistate Tax Commission’s efforts to modernize them. 

The authors explore the history of these industry-specific sourcing and apportionment provisions, recent proposals affecting some of those specific industries, such as trucking and airlines, and the challenges of applying special rules in an increasingly complex business environment.

Ultimately, they conclude that while these rules continue to serve an important purpose, changing business models and competing state tax policy goals may make uniformity more difficult to achieve.

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micheleborens@eversheds-sutherland.com

Michele Borens

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Washington, DC, United States

jeremygove@eversheds-sutherland.com

Jeremy P. Gove

Partner

New York, United States

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