The following apportionment factors will be utilized to recognize in and out-of-city performance in reference to those commissions earned as the result of stock sales:

Sale of Securities Apportionment Permissible for out-of-city Performance
Origination 60%
Execution 20%
Clearing 20%
  • The above activities must be performed by the taxpayer’s employees and not by independent contractors, or other third parties.
  • Stockbrokers trading on their own accounts
  • Gross receipts are determined by taking the total profits on transactions less the total losses on transactions without any other deductions. These trading profits are referred to under LAMC Section 21.49 (c) 6.