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2024 Schedule A-09 Instructions
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:
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, 2024, 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 2024,
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 2024, 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, 2024, 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
2024, 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
10a through 10l, 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 10a through 10l, 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
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