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Top Recent State Corporate Income Tax Cases: Nexus, Business Income, Combined Reporting, and Apportionment

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, October 27, 2022

Recorded event now available

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This course will provide tax professionals with an instructive review of the top recent state corporate income tax cases. Our panel will discuss SALT cases spanning substantive areas, including nexus, apportionment, non-business income, the tax base, sales factor sourcing, and unitary combined reporting.


Every year state tax auditors launch thousands of state corporate income tax audits. The audits focus on various substantive areas, including nexus, PL 86-272, business/non-business income distinctions, apportionment, sales factor assignment, the unitary business concept, and combined reporting.

The panelists selected recent SALT cases to review for their educational value and significance and include examples from California, New York, and many states in between.

Listen as our expert panel analyzes and dissects the most significant state corporate income tax cases that were not settled and proceeded to a litigated decision issued in 2021-2022.



  1. Summary of the case selection process
  2. Top nexus/PL 86-272 cases
  3. Top apportionment cases
  4. Top combined reporting cases
  5. Top tax base cases
  6. Top overall cases


The panel will discuss these and other essential questions:

  • Potential reasons why these cases were litigated and not settled
  • Key facts in the cases that were determinative of the outcome
  • Trends to derive from these cases
  • Lessons from the cases concerning meeting the burden of proof
  • Audit and state tax controversy tips from the cases


Cataldo, Michael
Michael J. Cataldo

Cataldo Tax Law

Mr. Cataldo represents corporate and individual clients in state and local tax controversies across the country during...  |  Read More

Reed, Jeffrey
Jeffrey S. Reed

Kilpatrick Townsend & Stockton

Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals...  |  Read More

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