By R. Gregory Roberts, Kenneth Levine and Jeremy Gove ( June 28, 2018, 11:06 AM EDT) -- In 2017, the Federal Communications Commission closed the first-ever broadcast spectrum "incentive auction" and television broadcasting businesses walked away with more than $10 billion of proceeds. Those businesses may have already filed their state corporate income tax returns for 2017 — or they may be getting ready to file those returns on extension — but either way, careful consideration should be given to how the auction proceeds should be treated for state tax apportionment purposes. Given the unique nature of these proceeds, the answer in many states might be that there is no clear answer. The purpose of this article is to call your attention to these areas and provide a framework for identifying potential opportunities that might exist as a result....