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
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.
Outline
- Summary of the case selection process
- Top nexus/PL 86-272 cases
- Top apportionment cases
- Top combined reporting cases
- Top tax base cases
- Top overall cases
Benefits
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
Faculty
Michael J. Cataldo
Shareholder
Cataldo Tax Law
Mr. Cataldo represents corporate and individual clients in state and local tax controversies across the country during... | Read More
Mr. Cataldo represents corporate and individual clients in state and local tax controversies across the country during audits, administrative appeals, litigation and settlement. He also provides state and local tax planning and transactional advice. His practice focuses primarily on state and local corporate income and franchise tax, sales and use tax, real property transfer tax, personal income tax and gross receipts tax imposed by jurisdictions throughout the country. He regularly represents and advises clients from a broad range of industries on issues such as nexus, apportionment, business/non-business income, unitary combined reporting, and the taxability and sourcing of transactions for sales and use taxes.
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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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