Instructions for 2023 Schedule A-01:  Wisconsin Single Sales Factor Apportionment 
                           Data for Nonspecialized Industries 
                                          
Purpose of Schedule A-01 

Corporations, partnerships, tax-option (S) corporations and nonresident estates, trusts, and individuals that are 
engaged in a unitary business both in and outside Wisconsin generally use Schedule A-01 to compute the factors 
that will determine their Wisconsin share of income from a unitary business.  

However,  taxpayers  in certain  specialized  industries  cannot  use  Schedule  A-01  because  the  Wisconsin 
Administrative Code requires them to apportion their income using more than one factor. These taxpayers must 
use one of the following schedules:  

• Schedule A-02, Wisconsin Apportionment Percentage for Interstate Financial Institutions,  
• Schedule A-03, Wisconsin Apportionment Percentage for Interstate Motor Carriers,  
• Schedule A-04,  Wisconsin Apportionment Percentage for Interstate Telecommunications Companies,  
• Schedule A-05, Wisconsin Premiums Factor for Insurance Companies,  
• Schedule A-06, Wisconsin Receipts Factor for Interstate Brokers-Dealers, Investment Advisors, Investment 
  Companies, and Underwriters,  
• Schedule A-07, Wisconsin Apportionment Percentage for Interstate Air Carriers,  
• Schedule A-08, Wisconsin Apportionment Percentage for Broadcasters,  
• Schedule A-09, Wisconsin Apportionment Percentage for Interstate Railroads,  
• Schedule A-10, Wisconsin Apportionment Percentage for Interstate Pipeline Companies,   or
• Schedule A-11,  Wisconsin Apportionment Percentage for Interstate Air Freight Forwarders Affiliated with a 
  Direct Air Carrier  

Taxpayers that use separate accounting cannot use Schedule A-01. See the instructions for Form C for more 
information on separate accounting.   

Special Instructions for Combined Groups 

Each corporation in a combined group must complete Schedule A-01, if applicable, to report the apportionment 
data for its own activities. The combined group then carries forward the amounts from each member’s Schedule A-
01 to Form 6, Part III, lines 1a and 1b to determine the combined group’s Wisconsin share of combined unitary 
income.  

Specific Instructions 

Only include amounts that are includable in the sales factor. Also, for lines 2b, 2c, and 3, you will need to compute 
the amount of throwback sales. The next two sections explain the sales factor and throwback sales. The line-by-
line instructions follow the explanation of throwback sales.  

Share of Apportionment Factors 

Partnerships, corporations, and tax-option (S) corporations must generally include their share of the numerator 
and denominator of  a  partnership’s apportionment factors  in the numerator and denominator  of their 
apportionment factors. Include these amounts using the Wisconsin apportionment Schedules A-01 through A-11, 
as appropriate. 

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                                     2023 Schedule A-01 Instructions 

Sales Factor in General 

Items Includable in Sales Factor. For purposes of the sales factor, sales include, but are not limited to, the 
following items related to the production of apportionable income: 
• Gross receipts from the sale of inventory. 
• Gross receipts from the operation of farms, mines, and quarries. 
• Gross receipts from the sale of scrap or by-products. 
• Gross commissions. 
• Gross receipts from personal and other services. 
• Gross rents from real property or tangible personal property. 
• Interest on trade accounts and trade notes receivable. 
• A member’s share of a limited liability company’s gross receipts or a partner’s share of a partnership’s gross 
  receipts. 
• Gross management fees. 
• Gross royalties from income producing activities. 
• Gross franchise fees from income producing activities. 

“Gross receipts” means gross sales less returns and allowances, plus service charges, freight, carrying charges, 
or time-price differential charges incidental to the sales. Federal and state excise taxes, including sales and use 
taxes, are included as part of the receipts if the taxes are passed on to the buyer or included as part of the selling 
price. 

Items Not Includable in Sales Factor. Do not include any of the following items in the sales factor: 
• Gross receipts and gain or loss from the sale of tangible business assets, except receipts from the sale of 
  inventory, scrap, or by-products or from the operation of a farm, mine, or quarry. 
• Gross receipts and gain or loss from the sale of nonbusiness real or tangible personal property. 
• Gross rents and rental income or loss from real property or tangible personal property if that real property or 
  tangible personal property isn’t used in the production of business income. 
• Royalties from nonbusiness real property or nonbusiness tangible personal property. 
• Proceeds and gain or loss from the redemption of securities. 
• Interest, except interest on trade accounts and trade notes receivable, and dividends. 
• Gross receipts and gain or loss from the sale of intangible assets, except inventory. 
• Dividends deductible in determining net income. 
• Gross receipts and gain or loss from the sale of securities. 
• Proceeds and gain or loss from the sale of receivables. 
• Refunds, rebates, and recoveries of amounts previously expended or deducted. 
• Foreign exchange gain or loss. 
• Royalties and income  from passive  investments in patents, copyrights, trademarks, trade names,  plans, 
  specifications, blueprints, processes, techniques, formulas, designs, layouts, patterns, drawings, manuals, 
  and technical know-how. 
• Pari-mutuel wager winnings and purses. 
• Other items not includable in apportionable income. For example: 
  o  Income derived from rentals and royalties from business or nonbusiness real estate or tangible personal 

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                                      2023 Schedule A-01 Instructions 

          property, or from the operation of any farm, mine or quarry, or from the sale of business or nonbusiness 
          real property or tangible personal property, are allocated to the location of the property from which derived. 
 o  Intangible  income such as interest and dividends, and gains and  losses resulting from the sale of 
          intangible property  such  as stocks, bonds, and securities which are passed through to  nonresident 
          partners aren’t taxable by Wisconsin because the income follows the residence of the individual. 
 o  All income that is realized from the sale of or purchase and subsequent sale or redemption of lottery prizes 
          if the winning tickets were originally bought in Wisconsin are allocated to Wisconsin. 
 o  Income  derived from casinos, bingo halls, and pari-mutuel winnings in Wisconsin  are allocated to 
          Wisconsin. 
 o  Income derived from a covenant not to compete is taxable to the extent that the covenant was based on 
          a Wisconsin-based activity. 
 o  Partnership income derived from personal services, including income from professional services. 
   
Throwback Sales  

A “throwback sale” is a taxpayer’s sale of tangible personal property destined for a state where the taxpayer has 
no nexus. If a sale is a throwback sale, it is included in the numerator of the sales factor as a Wisconsin sale.  

For purposes of determining throwback sales, a “state” is any state of the United States, the District of Columbia, 
the Commonwealth of Puerto Rico, and any United States territory or possession. A foreign country isn’t a “state.” 

Nexus in General. To determine if a taxpayer has nexus in another state for purposes of computing throwback 
sales, you would generally use the same rules that are used to determine if a similarly situated taxpayer would be 
subject to Wisconsin franchise or income tax if it made the sale to Wisconsin from another state. However, if the 
Wisconsin Statutes provide a specific exemption from nexus, such as in sec. 71.23(3), Wis. Stats., do not apply 
that Wisconsin statutory exemption when you determine if there is nexus in the destination state. 

A taxpayer engaged in the business of selling tangible personal property does not have nexus in any state where 
it  is protected from  taxation  under federal  Public Law 86-272 (P.L.  86-272).  See sec.  Tax 2.82, Wisconsin 
Administrative Code, for more details of P.L. 86-272 and a description of what constitutes nexus for Wisconsin 
franchise  or income tax  purposes.  Also see sec. Tax 2.39(6)(b), Wisconsin Administrative  Code, for more 
information about the relationship between nexus and throwback sales.   

Nexus and Throwback Sales for Combined Groups. In a combined group, nexus is determined for the unitary 
business as a whole. Therefore, a combined group member’s sales destined outside Wisconsin cannot be “thrown 
back” to Wisconsin if any member of the  combined  group has nexus  relating to the unitary business  in the 
destination state. The example below illustrates:  

Example:  
Corporation B has an office and inventory in Wisconsin, but when considered as a separate entity, it does not 
have any property or nexus-creating activity outside Wisconsin. However, Corporation B is in Combined Group 
BC, which consists of Corporations B and C. Corporation C has an office and retail store in Illinois, which are part 
of the same unitary business as B’s Wisconsin office and inventory.  

Assume that B sells a widget to a customer located in Illinois and ships it by common carrier to the customer’s 
Illinois address. Corporation B should not include that sale in its sales factor numerator as a throwback sale. Since 
C has nexus in Illinois that relates to Combined Group BC’s unitary business, B is also deemed to have nexus in 
Illinois. 

See  secs. Tax 2.61(7), and 2.82(5), Wisconsin  Administrative Code, for further details of  how nexus and 
throwback sales are determined for combined groups.  
 
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                                          2023 Schedule A-01 Instructions 

Line-by-Line Instructions  

■ Lines 1a and 1b. Tangible Personal Property Destined for Wisconsin – For the Wisconsin column, enter 
the amounts of Wisconsin destination sales. Gross receipts from the sales of tangible personal property, except 
sales to the federal government, are Wisconsin sales if the property is delivered or shipped to a purchaser in 
Wisconsin.  

Wisconsin sales include sales of tangible personal property that are picked up by the purchaser, or the purchaser’s 
agent, at the seller’s out-of-state business location and immediately transported to the purchaser’s Wisconsin 
business location. 

Wisconsin sales do not generally include sales of tangible personal property picked up by the purchaser, or the 
purchaser’s agent, at the seller’s Wisconsin business location if the property is immediately transported to the 
purchaser’s out-of-state business location. However, if the seller doesn’t have nexus with the state where the 
purchaser’s business is located, the sales are “thrown back” to Wisconsin. 

■ Line 2a. Sales to Federal Government in Wisconsin – For the Wisconsin column, enter the amount of sales 
of tangible personal property delivered to the federal government, including its agencies and instrumentalities, in 
Wisconsin if the property is shipped from an office,  store, warehouse, factory, or other place  of storage in 
Wisconsin.  Sales to federal  government  locations in  Wisconsin,  which are shipped from an  office, store, 
warehouse, factory, or other place of storage outside Wisconsin, aren’t Wisconsin sales. 

■ Line 2b. Throwback Sales to Federal Government – For the Wisconsin column, enter the amount of sales of 
tangible  personal property delivered to  the federal government,  including  its agencies and instrumentalities, 
outside Wisconsin if the property is shipped from an office, store, warehouse, factory, or other place of storage in 
Wisconsin and the seller doesn’t have nexus in the destination state.  

■ Line 2c. Throwback Sales –    For the Wisconsin column, enter the amount of sales, other than sales to the 
federal government, that are “thrown back” to Wisconsin. These are sales of tangible personal property shipped 
from an office, store, warehouse, factory, or other place of storage in Wisconsin to a state in which the seller 
doesn’t have nexus.  

■ Line 3. Double Throwback Sales – For the Wisconsin column, enter the amount of “double throwback” sales. 
These are sales of tangible personal property, other than sales to the federal government, which were made by 
an office in Wisconsin but not shipped or delivered from Wisconsin,  ifthe taxpayer doesn’t have nexus in either 
the destination state or the state from which the property is shipped or delivered.  

■ Line 5. Receipts from Use of Computer Software – For the Wisconsin column, enter the amount of gross 
receipts from the use of computer software that the purchaser or licensee uses at a  location  in  Wisconsin. 
Computer software is used in Wisconsin if the purchaser or licensee uses the software in the regular course of 
business operations in Wisconsin, for personal use in Wisconsin, or if the purchaser or licensee is an individual 
whose domicile is in Wisconsin. 

If the purchaser or licensee uses the computer software in more than one state, the gross receipts are divided 
among those states having jurisdiction to impose an income tax on the taxpayer in proportion to the use of the 
computer software  in those states. To determine computer software use in  Wisconsin, the Department  may 
consider the number of users in each state where the software is used, the number of site licenses or workstations 
in Wisconsin, and any other factors that reflect the use of computer software in Wisconsin. 

■ Line 6. Receipts from Use of Computer Software –       For the Total Company column, enter the amount of 
gross receipts from the use of computer software by the purchaser or licensee everywhere.   

■ Line 7. Receipts from Services – For the Wisconsin column, enter the amount of gross receipts from services 
if the purchaser of the service received the benefit of the service in  Wisconsin. The benefit  of the service is 
received in Wisconsin if any of the following applies: 
•  The service relates to real property that is located in Wisconsin. 
    
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                                    2023 Schedule A-01 Instructions 

• The service relates to tangible personal property that  is delivered  directly or  indirectly  to customers  in 
  Wisconsin. 
• The service is purchased by an individual who is physically present in Wisconsin at the time that the service 
  is received. 
• The service is provided to a person engaged in a trade or business in Wisconsin and relates to that person’s 
  business in Wisconsin. 

If the purchaser of a service receives the benefit of the service in more than one state, the gross receipts from the 
service are included in the numerator  of the sales factor according to the portion  of the service received in 
Wisconsin. 

■ Line 8. Receipts from Services – For the Total Company column, enter the amount of gross receipts from 
services everywhere. 

■ Line 9. Other Apportionable Gross Receipts –      For both Wisconsin and the Total Company columns, enter 
the amount of other gross receipts of apportionable income that are includable in the sales factor. These gross 
receipts may include: 
• Leases, rentals, or licensing of tangible personal property, including moving property. 
• Sales, leases, rentals, or licensing of real property. 
• Sales of intangible property. 
• Royalties, licensing or allowing the use of intangible property. 

In general, these gross receipts are in Wisconsin in proportion to the purchaser’s use of or benefit from the property 
in Wisconsin. See sec. Tax 2.39(6)(c), (d), (h), and (i), Wisconsin Administrative Code, for further details on how 
to determine the amount of these other apportionable gross receipts in Wisconsin.   

■ Line 11. Apportionment Percentage (Separate return filers and pass-through entities) –   Divide Wisconsin 
column, line 10, by Total Company column, line 10, and multiply that amount by 100. Fill all spaces to the right 
of the decimal point.  Round to the nearest ten-thousandth of a percent (for  example, 12.3456%).  See the 
instructions of the tax  form you are filing (Form 1NPR, 2, 3, 4, 4T, 5S, or  6) for  how to report  and use this 
percentage. 

Conversion to Modified Sales Factor 

Combined return filers complete lines 12 through 17 to compute the “modified sales factor” that will determine 
their Wisconsin share of combined unitary income.   

■ Line 12. Intercompany Sales (Combined Group Members Only) – Any sales made between members of the 
same combined group (“intercompany sales”), either directly or through interests in a pass-through entity, must 
be excluded from the amounts you entered on lines 1 through 9. 

Report the excluded amount of intercompany sales on line 12. If you already excluded these intercompany sales 
from the amounts you entered on lines 1 through 9, do not enter any amounts on line 12.  

Following are additional details about intercompany transactions that involve pass-through entities. For additional 
information, refer to sec. Tax 2.61(7)(e), Wisconsin Administrative Code. 

Sales to Pass-Through Entities Owned by Combined Group Members. If a combined group member makes 
a sale to a pass-through entity which is more than 50 percent owned, directly or indirectly, by members of the 
combined group, the member must eliminate an amount equal to the gross receipts of the sale multiplied by the 
sum of all combined group members’ interests in the pass-through entity as of the date of the sale. The examples 
below illustrate: 

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                                           2023 Schedule A-01 Instructions 

Example 1: Combined Group LM consists of Member L and Member M. L owns a 40% interest in Partnership P. 
M owns a 60% interest in Partnership P. On March 1, 2023, L sells a widget to Partnership P for $10,000, and this 
sale is includable in Group LM’s combined unitary income. In its computation of apportionment factors for 2023, 
L must subtract  an amount of $10,000 (= $10,000 x (40% + 60%)) from  its sales factor denominator and, if 
applicable, from its numerator. 

Example 2: Assume the same facts as Example 1, except that Member L owns a 25% interest and M owns a 50% 
interest in Partnership P. In its computation of apportionment factors for 2023, L must subtract an amount of 
$7,500 (= $10,000 x (25% + 50%)) from its sales factor denominator and, if applicable, from its numerator. 

Sales by Pass-Through Entities Owned by Combined Group Members. If a pass-through entity makes a sale 
to a combined group member and more than 50 percent of the pass-through entity is directly or indirectly owned 
by members of the combined group, each member with an interest in the pass-through entity must subtract from 
its sales factor numerator and denominator any amount that would otherwise be included attributable to the sale. 
The example below illustrates: 

Example: Combined Group ST consists of Member S and Member T. S owns a 20% interest in Partnership R. T 
owns an 80% interest in Partnership R. On October 1, 2023, Partnership R sells a widget to S for $20,000, and 
this sale is includable in Group ST’s combined unitary income. In its computation of apportionment factors for 
2023, S must subtract an amount of $4,000 (= $20,000 x 20%) from its sales factor denominator and, if applicable, 
from its numerator. Similarly, T must subtract an amount of $16,000 (= $20,000 x 80%) from its sales factor 
denominator and, if applicable, from its numerator. 

■  Line  13.  Sales  Excluded  from  Combined  Unitary  Income  (Combined Group Members Only)  –  If you 
reported an amount on Form 6, Part II, line 6 for separately apportioned income, you must exclude the sales 
attributable to that amount from the numerator and denominator of the sales factor, as applicable. Report the 
excluded amount of these sales on line 13. However, if you already excluded these sales from the amounts you 
entered on lines 1 through 9, do not enter any amounts on line 13.  

See the instructions to Form N, Wisconsin Nonapportionable, Separately Accounted, and Separately Apportioned 
Income, for further details on how to report and apportion separately apportioned income. 

■ Line 16. Sales Previously Deferred (Combined Group Members Only) – If a combined group member made 
a sale to another member of the combined group in a prior taxable year and gain or loss on the transaction was 
deferred under the provisions of sec. 71.255(4)(g), Wis. Stats., the selling member must include the gross receipts 
from the sale in its sales factor in the year the gain or loss is recognized, to the extent those gross receipts are 
otherwise includable in the sales factor.  

 NOTE: Section 71.255(4)(g), Wis. Stats., provides that the intercompany deferral provisions of Treas. Reg. 
 §1.1502-13 apply to a combined group similarly to how they apply to a consolidated group for federal purposes. 
 See the instructions to Form 6, Part I, line 33, for details.  
                                                                                                                 
Report the gross receipts corresponding to any income recognized under sec. 71.255(4)(g), Wis. Stats., on line 16. 
If you already included these receipts in the amounts you entered on lines 1 through 9, do not enter any amounts 
on line 16.  

Under sec. Tax 2.61(7)(d), Wisconsin Administrative Code, special sourcing rules apply to amounts reported on 
line 16. If  a combined group member sells an item  or service to another combined group member and  the 
purchaser subsequently resells it to a third party outside of the group, the situs of both sales is determined based 
on the situs of the sale from the purchasing member to the third party. Also, the purchasing member must exclude 
from its apportionment factors the amount the selling member already included attributable to that same item or 
service. The example below illustrates:  
 
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                                          2023 Schedule A-01 Instructions 

Example:  
Combined Group YZ consists of Member Y and Member Z. Group YZ is on a calendar year. On December 30, 
2022, Y sells a widget with a cost of $400 to Z, for $600. Y ships the widget to Z’s warehouse in Wisconsin. On 
January 30,  2023, Z resells the widget to Q,  an  unrelated third party, for $700. Z ships the widget to  Q’s 
headquarters in Illinois. Assume both the sale by Y and the sale by Z are includable in combined unitary income, 
and assume that Z has nexus in Illinois.  

In 2022, Y did not recognize any gain on the sale to Z because the gain was deferred under the provisions of sec. 
71.255(4)(g), Wis. Stats. Since the gain on the sale was not recognized, Y cannot include the $600 sale in its 
apportionment factors for 2022.  

In 2023, Y must include its $200 of gain on the sale to Z (= $600 - $400) in combined unitary income. Y must also 
include the sale amount of $600 in its sales factor denominator for 2023. Z must include its $100 gain on the sale 
to Q (= $700 - $600) in combined unitary income for 2023. However, since $600 of Z’s sales price has already 
been included in Y’s sales factor, Z may only include the remaining $100 of the sale amount in its sales factor 
denominator. Neither Y nor Z include these amounts in their sales factor numerators since both sales are deemed 
to have a situs in Illinois where Group YZ has nexus.  

Additional Information and Assistance 
 
Web Resources  
 
The Department of Revenue’s web page, available at revenue.wi.gov, has several resources to provide additional 
information and assistance, including: 
 
• Related forms and their instructions  
• Common questions  
• Publications on specific tax topics 
• The Wisconsin Tax Bulletin  
• A home page specifically for combined reporting topics 
• Links to the Wisconsin Statutes and Administrative Code 
 
Contact Information  
 
If you cannot find the answer to your question in the resources available on the Department of Revenue’s web 
page, contact the Department using any of the following methods: 
 
• E-mail your question to: DORFranchise@wisconsin.gov 
• Call (608) 266-2772  
  (Telephone help is  also  available using TTY  equipment. Call the Wisconsin  Telecommunications Relay 
  System at 711 or, if no answer, (800) 947-3529. These numbers are to be used only when calling with TTY 
  equipment.) 
• Send a fax to (608) 267-0834 
• Write to the Audit Bureau, Wisconsin Department of Revenue, Mail Stop 3-107, PO Box 8906, Madison, WI  
  53708-8906 
                                          Applicable Laws and Rules 

  This document provides statements or interpretations of the following laws and regulations enacted as 
  of December 1, 2023:  Chapter 71 Wis. Stats., and Chapter Tax 2, Wis. Adm. Code 

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