Navigating the Apportionment Landscape After Maryland v. Wynne: Maximizing Tax Credit Opportunities
Recording of a 110-minute CPE webinar with Q&A
This course will provide state tax professionals with an update of the latest trends in state apportionment issues after the U.S. Supreme Court’s landmark decision in Comptroller of the Treasury of Maryland v. Wynne. The Court’s holding provided a major victory for individual taxpayers who receive income from multiple jurisdictions, and will positively impact similarly situated taxpayers in other jurisdictions. Tax advisers must be aware of the evolving nature of apportionment to avoid paying excess and unnecessary tax.
Outline
- Wynne holding in detail
- Treating other state and local taxes as creditable state tax
- Internal consistency test criteria
- External consistency test criteria
- Changes to apportionment formulas
- Criteria and process to claim refunds for taxes paid under previous regime (Maryland and other jurisdictions)
Benefits
The panel will discuss these and other important topics:
- What was the basis for the apportionment challenge made by the taxpayers?
- How will the Wynne decision affect multistate tax professionals?
- Additional apportionment developments after Wynne
Faculty
Christopher L. Doyle
Partner
Hodgson Russ
Mr. Doyle leads his firm's SALT team. His practice spans most tax matters, but focuses primarily on New York... | Read More
Mr. Doyle leads his firm's SALT team. His practice spans most tax matters, but focuses primarily on New York State and New York City business taxes, including corporate income tax, unincorporated business tax, flow-through entity income taxation, and sales and use taxes. He provides counsel for tax-wise transaction structuring as well as tax controversy representation at every level, from audit representation to representation before New York's Court of Appeals. He is a former instructor of tax practice and procedure at the University of Buffalo School of Management.
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Debra Silverman Herman
Partner
Hodgson Russ
Ms. Herman is widely recognized for her experience in state and local taxation. She works with a variety of... | Read More
Ms. Herman is widely recognized for her experience in state and local taxation. She works with a variety of clients to address the state and local tax impact of their multistate activities from both a planning and an audit and controversy viewpoint and on complex transactions. She counsels clients with respect to corporate income and franchise taxes, bank taxes, utility taxes, unincorporated business taxes, sales and use taxes, gross receipts taxes, excise taxes on real property transfers, rent and occupancy taxes, and withholding taxes. She is also a nationally recognized author on state tax topics.
CloseAlexandra P.E. Sampson
Reed Smith
Ms. Sampson is a member of the firm's State Tax Group. Her practice includes state and local tax... | Read More
Ms. Sampson is a member of the firm's State Tax Group. Her practice includes state and local tax compliance, audits, appeals and litigation. She advises clients on complex multistate issues spanning the corporate income, franchise and business, sales and use, and property tax areas.
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