Instructions for 2023 Schedule A-06:   
  Wisconsin Receipts Factor for Interstate Brokers-Dealers, Investment Advisors, 
                             Investment Companies, and Underwriters 
 
  Purpose of Schedule A-06                                                                                              
 
  Interstate  broker-dealers,  investment  advisors,  investment  companies,  and  underwriters  required  to  use 
  apportionment must use the factor prescribed in sec. Tax 2.495, Wis. Administrative Code. 
 
   Line-by-Line Instructions                                                                                            

  Share of Apportionment Factors 

  Partnerships, corporations, and tax-option (S) corporations must generally include their share of the numerator 
  and denominator of the  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. 
 
  Line 1. Gross Brokerage Commissions    – For the Wisconsin column, include gross brokerage commissions 
  earned if the billing address of the customer is in Wisconsin. 
 
  For the Total Company column, include gross brokerage commissions earned everywhere. 
 
  Line 2. Gross Margin Interest Earned – For the Wisconsin column, include total margin interest earned on behalf 
  of brokerage accounts owned by customers if the billing address of the customer is in Wisconsin. 
 
  For the Total Company column, include the total margin interest earned on behalf of brokerage accounts owned 
  by customers everywhere. 
 
  Line 3.  Gross Account  Maintenance Fees – For the Wisconsin column,  enter account  maintenance fees 
  received on behalf  of  brokerage  accounts  owned by customers  if the billing  address of the customer is in 
  Wisconsin. 
 
  For the Total Company column, enter account maintenance fees received on behalf of brokerage accounts owned 
  by customers everywhere. 
 
  Line 4. Gross Receipts, Net of Commissions, from Sales of Trading Assets – Gross receipts from sales of 
  trading  assets (net of commissions)  are sourced  based  on  either  the taxpayer's commercial domicile or the 
  customer's billing address. Check the box on line 4 to indicate the elected method. Once the election is made, it 
  must be used for all future taxable years unless the department approves a change in method. 
 
  If the election is made to source trading assets net of commissions based on commercial domicile:           For 
  the Wisconsin column, include gross receipts, net of commissions, from sales of trading assets, if the day-to-day 
  decisions regarding the trading assets occur at a location in Wisconsin. If the day-to-day decisions regarding the 
  trading assets occur at locations both in and outside Wisconsin, the assets are considered located at the location 
  where the trading policies and guidelines are established. It is rebuttably presumed that the location where the 
  trading policies and guidelines are established is at the taxpayer's commercial domicile. 
 
  For the Total Company column, include gross receipts, net of commissions, from sales of all trading assets. 
 
  “Commercial domicile" means the location from which a trade or business is principally managed and directed. If 
  the taxpayer is organized under the laws of a foreign country, the commonwealth of Puerto Rico, or any territory 
  or possession of the United States, “commercial domicile" shall be deemed for the purposes of this section to be 
  the state of the United States or the District of Columbia from which the taxpayer's trade or business in the United 
  States is principally managed and directed. It shall be rebuttably presumed that the location from which a trade or 

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                                           2023 Schedule A-06 Instructions 

 business is principally managed and directed is the state of the United States or the District of Columbia at which 
 the greatest number of the taxpayer's employees work, have their office or base of operations, or are directed or 
 controlled, as of the last day of the taxable year. 
 
 If the election is made to source trading assets  net of commissions based on the customers billing 
 address: For the Wisconsin column, include gross receipts, net of commissions, from sales of trading assets if 
 the customer's billing address is in Wisconsin. Once made, the election cannot be revoked without prior consent 
 from the department. If a  request to change an election has  been approved by the department, the change 
 becomes effective with the first taxable year ending on or after approval by the department. 
 
 Note: 2023 Wis. Act 19 created a new rule to provide that in certain instances the department cannot order or permit 
 the substitution of net gains for gross receipts in the receipts factor if the use of gross receipts results in substantial 
 distortion of the taxpayer's receipts factor.  
  
 Specifically, the department cannot substitute net gains if any taxpayer who, before January 1, 2023, elected to 
 source its sales of trading assets using the customer billing address method defined in sec. Tax 2.495(4)(d)1m., 
 Wis.  Adm. Code, if the taxpayer has not revoked that election, and who, for  any taxable year beginning after 
 December 31, 2021, determines its receipts factor under sec. Tax 2.495(4), Wis. Adm. Code, by using the average 
 of the receipts factor determined  by using (a) gross receipts, net of commissions, and (b) net gain, net  of 
 commissions, from sales of trading assets for the taxable year, with all other components of the receipts factor under 
 sec. Tax 2.495(4), Wis. Adm. Code, remaining the same. Any such taxpayer may compute its receipts factor under 
 this new rule using that averaging method. The department cannot require any taxpayer who elected before January 
 1, 2023, to use the customer billing address method for sourcing sales of trading assets, if the taxpayer has not 
 revoked that election, to use any other method of determining its receipts factor under sec. Tax 2.495(4), Wis. Adm. 
 Code. 
  
 See sec. Tax 2.495(4)(d)3., Wis. Adm. Code, for information. If using this exception, enter the average of the receipts 
 factor and include a schedule detailing the computation. 
 
 For the Total Company column, include gross receipts, net of commissions, from sales of all trading assets. 
 
 Line 5. Gross Receipts  Received on Investment Contracts       – For the  Wisconsin column,  include gross 
 payments received on investment contracts issued by the taxpayer and held by customers if the billing address 
 of the customer is in  Wisconsin. “Investment contract" includes  any  bonds, shares, coupons, certificates of 
 membership, or other obligations or agreements issued by the taxpayer to return to the holders or owner's money 
 or anything of value at some future date. 
 
 For the Total Company column,  include  all gross  payments  received on investment  contracts issued by the 
 taxpayer and held by customers, regardless of billing address. 
 
 Line 6. Gross Receipts from Underwriting Services   –    The Wisconsin column of the receipts factor includes 
 gross receipts, including gross commissions, gross management fees, or gross underwriting fees, earned in 
 performing underwriting activities on behalf of the issuer of the securities if either of the following applies: 
 
 • The issuer  of the securities is not engaged  in  a trade or business, and the issuer's billing address is in 
   Wisconsin. 
 • The issuer of the securities is engaged in a trade or business, the issuer of the securities maintains a regular 
   place of business  in  Wisconsin, and  the securities relate to that person's  business in Wisconsin. If the 
   securities relate  to  that person's regular place of business in  more  than  one state, the receipts from the 
   performance of the service are included in the numerator of the receipts factor according to the portion of  the 
   service received  in  Wisconsin. If  the regular place  of business to which the  securities relate cannot be 
   determined, the service is received in Wisconsin if the issuer of the securities, in the regular course of the 
   issuer's business, ordered the service from an office in Wisconsin. If the ordering office cannot be determined, 
   the service is received in Wisconsin if the issuer's billing address is in Wisconsin. 
 
 The Total Company column includes gross receipts, including gross commissions, gross management fees, or 
 gross underwriting fees, earned in performing underwriting activities on behalf of the issuer of the securities. 
 
 Line 7. Other Gross Receipts – The Wisconsin column and Total Company column includes other gross receipts 
 or net gains such as:  gross receipts from the lease of real property; gross receipts from the lease of tangible 
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                                         2023 Schedule A-06 Instructions 

 personal property; gross interest and other fees from loans secured by real property; gross interest and other fees 
 from loans secured by tangible personal property; gross interest and other fees from loans not secured by real or 
 tangible personal property; net gains from the sale of loans; gross receipts from credit card receivables; net gains 
 from the sale of credit card receivables; credit card issuer's reimbursement fees; gross receipts from merchant 
 discount; loan servicing fees; gross receipts from travelers checks, cashier's checks, certified checks, and money 
 orders; gross receipts from automated teller machines; gross receipts from safety deposit boxes; gross receipts from 
 maintaining  accounts;  gross receipts from  electronic funds transfer; gross receipts from cash management 
 services; gross receipts from international trade services; gross receipts from data processing services, document 
 imaging services, and microfilming services; gross receipts from research services; gross receipts from trust 
 services; gross receipts from investment banking services; gross receipts from security brokerage services; gross 
 receipts from other services; gross receipts from computer software; gross royalties and other gross receipts from 
 intangibles; gross receipts from services provided to regulated investment companies; and other sales.  For 
 additional detail, see sec. Tax 2.94(4), Wis. Admin. Code. 
 
 Line 8. 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 

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                                       2023 Schedule A-06 Instructions 

  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, use the same rules 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.   
 
  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. 
 
  Line 10. Apportionment Percentage (separate return filers and pass-through entities) – Divide Wisconsin 
  column, line 9, by Total Company column, line 9, 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 being filed (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 only)                                                    
 
  Line 11. 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 entered on lines 1 through 8. 
 
  Report the excluded intercompany sales on line 11. If these intercompany sales are already included on lines 1 
  through 8, do not enter any amounts on line 11. 
   
  Additional details about intercompany transactions involving pass-through entities are presented below and 
  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-06 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 $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 $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 $4,000 (= $20,000 x 20%) from its sales factor denominator and, if applicable, from its 
 numerator. Similarly, T must subtract $16,000 (= $20,000 x 80%) from its sales factor denominator and, if 
 applicable, from its numerator. 
 
 Line 12. Sales Excluded from Combined Unitary Income (Combined Group Members Only) – If sales are 
 included on Form 6, Part II, line 6 (separately apportioned income) those sales are excluded from the numerator 
 and denominator of the sales factor. Report the excluded amount of these sales on line 12.  
  
 However, if these excluded sales are entered on lines 1 through 8, do not enter any amounts on line 12. 
 
 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 15. 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 15. If sales are already included these receipts in the amounts entered on lines 1 through 8, do not enter any 
 amounts on line 15. 
 
 Under sec. Tax 2.61(7)(d), Wisconsin Administrative Code, special sourcing rules apply to amounts reported on 
 line 15. 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 

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                                          2023 Schedule A-06 Instructions 

 exclude from its apportionment factors the amount the selling member already included attributable to that same 
 item or service. The example below illustrates: 
 
 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 a number of 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) 267-0834f 
 • 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 
  the revision date:  Chapter 71 Wis. Stats., and Chapter Tax 2 and Chapter 3, Wis. Adm. Code 

 IC-806 (R. 12-23)