SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will offer tax professionals insight and guidance on state tax implications for transactions and activities of multinational businesses. The panel will discuss the impact of deemed tax residency, business apportionment, certain selective add-backs to income, tax implications arising from international provisions of federal tax reform, and planning methods related to state and local taxation of foreign corporation revenue within a given forum.
Outline
- Analysis and impact of tax residency status and establishing procedures for forum compliance
- State subjection of foreign corporations and subsidiaries to taxation, including unitary taxation
- Business apportionment and waters-edge election
- State tax haven legislation updates
- Preliminary observations on state and local tax implications of federal tax reform
Benefits
The panel will review these and other key issues:
- Recognizing the exposure and effect of state taxation on foreign corporations
- Identifying state tax legislation and reporting requirements of subsidiaries and affiliated groups
- Ascertaining the available methods to reduce and limit state tax liability
Faculty
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Jeffrey S. Reed
Partner
Kilpatrick Townsend & Stockton
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals... | Read More
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the U.S. He brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. He is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.
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