Corporate Apportionment and Sourcing Rights in Multistate Tax Compact States
Key Implications Triggered by California's Gillette Case
Recording of a 110-minute CPE webinar with Q&A
This teleconference will explore the important multistate corporate income tax implications arising from controversies about how closely member states must track the Multistate Tax Compact on apportionment and sourcing.
California's Gillette case
- FTB's apportionment formula vs. MTC 3-factor apportionment
- Status of state supreme court appeal
Implications with sourcing of revenue from services and sales of intangible assets
- Parallel issues with what sections of MTC agreements say on sourcing
Issues with other state cases and administrative guidance on similar issues
- Michigan's IBM decision
- Oregon Revenue Department guidance on protective refund claims
- Other examples
Practical decisions for multistate companies
- Protective refund claims
- Taking positions on original or amended returns in member states
- Potential for additional penalties and interest if unsuccessful
The panel will address issues such as these:
- What rights do certain sections of the MTC agreement give to corporate income taxpayers filing in MTC member states?
- What happens when a member state decides to take a different direction on apportionment or sourcing than the MTC does?
- What actions can a company prudently consider regarding positions on returns in MTC member states, based on the recent legal battles?
- What are the risks with taking those positions, if circumstances change?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Bradley Arant Boult Cummings
He has more than 30 years of experience handling federal and state tax compliance and planning matters for large... | Read More
He has more than 30 years of experience handling federal and state tax compliance and planning matters for large corporate clients and projects. He particularly focuses on taxpayer representation in federal, state and local administrative and judicial forums; business entity selection; and responses to new tax legislation. He also is a frequent writer and speaker on SALT topics.Close
Faegre Baker Daniels
He has more than 30 years of experience representing business clients on federal and state tax matters, in disputes at... | Read More
He has more than 30 years of experience representing business clients on federal and state tax matters, in disputes at the administrative level and in court.Close
Crowell & Moring
He works with corporate tax executives, some at Fortune 500 companies, on state and local tax issues and tax... | Read More
He works with corporate tax executives, some at Fortune 500 companies, on state and local tax issues and tax controversies. He is a frequent speaker at TEI and COST events and also serves as an adjunct law professor at Georgetown University.Close
Crowell & Moring
He represents corporations, partnerships and individuals in tax matters, particularly involving multi-state tax... | Read More
He represents corporations, partnerships and individuals in tax matters, particularly involving multi-state tax planning, consulting and controversies.Close