42nd Institute on State and Local Taxation 2023 (presented by NYU School of Professional Studies) [Day 2]

Michael J. Bryan, CPA
Robert M. Porcelli, Esq.
David J. Shipley, Esq.
Nicole M. Wooten, Esq.
Michael J. Hilkin, Esq.
Dana Lance, CPA
Eric M. Anderson, Esq.
Michael J. Semes, Esq.
Ali R. Vahdat, Esq.
Bruce J. Fort, Esq.
Alysse McLoughlin, Esq.
Jeffrey A. Friedman, Esq.
Richard D. Pomp, Esq.
Lindsay LaCava, Esq.
Aliza L. Sherman, Esq.
Chris Barber, Esq.
Dale Y. Kim, CPA
Kelvin M. Lawrence, Esq.
Ted W. Friedman, Esq.
Jack Trachtenberg, Esq.
Richard C. Call, Esq.
Harley T. Duncan
Brian L. Oliner, Esq.
Justin Pierce Berutich, Esq.
Tov Haueisen, Esq.
Jenny Wong, Esq.
Jackie C. Orea
Jennifer S. White, Esq.
Kimberley A. Wick, CPA
Amanda Hiller, Esq.
Marita R. Sciarrotta, MPA
John Biello, MPA
Stephanie Anne Lipinski Galland, Esq
Burnet R. Maybank III, Esq.
Sharon R. Paxton, Esq.
Leah Robinson, Esq.
Jorge Rodriguez, Esq.
Timothy G. Schally, Esq.
Mark F. Sommer, Esq.
Josh Veith, Esq.
Geoffrey Way, Esq.
Masha M. Yevzelman, Esq.
Jaye A. Calhoun, Esq.
Karl A. Frieden, Esq.
Michael Garcia
Michael J. Bryan, CPA | Trenton
Robert M. Porcelli, Esq. | PwC
David J. Shipley, Esq. | Stevens & Lee
Nicole M. Wooten, Esq. | Maynard Nexsen PC.
Michael J. Hilkin, Esq. | McDermott Will & Emery
Dana Lance, CPA | Grant Thornton
Eric M. Anderson, Esq. | Andersen Tax
Michael J. Semes, Esq. | BakerHostetler
Ali R. Vahdat, Esq. | Ernst & Young
Bruce J. Fort, Esq. | Multistate Tax Commission
Alysse McLoughlin, Esq. | Jones Walker
Jeffrey A. Friedman, Esq. | Eversheds Sutherland US
Richard D. Pomp, Esq. | University of Connecticut
Lindsay LaCava, Esq. | Baker McKenzie
Aliza L. Sherman, Esq. | Stevens & Lee
Chris Barber, Esq. | Multistate Tax Commission
Dale Y. Kim, CPA | Ernst Young LLP.
Kelvin M. Lawrence, Esq. | Dinsmore & Shohl
Ted W. Friedman, Esq. | Eversheds Sutherland US
Jack Trachtenberg, Esq. | Deloitte Tax
Richard C. Call, Esq. | McDermott Will & Emery
Harley T. Duncan | KPMG
Brian L. Oliner, Esq. | Federation of Tax Administrators
Justin Pierce Berutich, Esq. | Transactional
Tov Haueisen, Esq. | PwC US
Jenny Wong, Esq. | Ryan Transactional Risk
Jackie C. Orea | Andersen Tax
Jennifer S. White, Esq. | Reed Smith
Kimberley A. Wick, CPA | KPMG
Amanda Hiller, Esq. | New York State Department of Taxation and Finance
Marita R. Sciarrotta, MPA | Trenton
John Biello, MPA | Connecticut Department of Revenue Services
Stephanie Anne Lipinski Galland, Esq | Miles Stockbridge
Burnet R. Maybank III, Esq. | Nexsen Pruet
Sharon R. Paxton, Esq. | McNees Wallace & Nurick
Leah Robinson, Esq. | Mayer Brown
Jorge Rodriguez, Esq. | Rodriguez Law Firm
Timothy G. Schally, Esq. | Michael Best & Friedrich, Milwaukee
Mark F. Sommer, Esq. | Frost Brown Todd
Josh Veith, Esq. | Ryan Law
Geoffrey Way, Esq. | KPMG
Masha M. Yevzelman, Esq. | Fredrickson & Byron
Jaye A. Calhoun, Esq. | artner, Kean Miller, New Orleans, LA
Karl A. Frieden, Esq. | Council On State Taxation
Michael Garcia | Ryan

On-Demand: December 11 – December 12, 2023

42nd Institute on State and Local Taxation 2023 (presented by NYU School of Professional Studies) [Day 2]
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Program Summary

The Institute provides the perfect setting to meet practitioners from around the country. It’s an opportunity to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education. At the Institute, you will:

Key topics to be discussed:

  • Learn about the year’s most important state and local tax developments from a national perspective.
  • Obtain up-to-date analyses of state tax policy issues.
  • Explore the most important professional challenges and ethical dilemmas that are reshaping the profession.
  • Develop a working knowledge of the current trends in areas of state and local taxation, such as transfer pricing controversies; tangible personal property; tax insurance; sales and use tax compliance; and more.

This course is co-sponsored with myLawCLE.

Date: December 11, 2023

Date: December 12, 2023

Closed-captioning available

Speakers

Michael J. Bryan, CPA_myLawCLEMichael J. Bryan, CPA | Trenton

A multi talented tax professional with nearly 30 years of public accounting, industry and government experience. I can provide a unique perspective on your multistate and federal tax challenges.

 

Robert M. Porcelli, Esq. _PwC_myLawCLERobert M. Porcelli, Esq. |PwC

Rob is a Tax Partner with over 22 years of experience in state and local tax consulting.

He is a trusted advisor to businesses in multiple sectors, and his work with them includes multistate tax consulting, planning and analyzing complex tax issues, preparing tax memoranda and tax opinions, creating and implementing corporate strategies, and reviewing state and local tax financial statement provisions and tax returns. He is also active in the state tax controversy practice where he has assisted clients with resolving state tax audits and represented clients before various state administrative boards.

Clients value Rob for his knowledge, integrity, and passion for delivering attentive service. With a natural talent for developing deep and trusted relationships, he is approachable, available, team oriented, and thrives on collaboration. On engagements, Rob is adept at working with clients to address complex state and local tax problems and develop strategies and solutions to meet the specific and individual needs of their businesses.

Rob is also a speaker, instructor, and author on multistate taxation for various groups. He is licensed to practice law in New Jersey and Pennsylvania.

 

David J. Shipley, Esq._ Stevens & Lee_myLawCLEDavid J. Shipley, Esq. | Stevens & Lee

David is the Co-Chair of Stevens & Lee’s State and Local Tax Group. He focuses on representing clients in complex state tax controversies during audits, before administrative boards and in courts across the country. David also provides sophisticated multistate tax advice to his clients regarding their business operations, assists with navigating the state tax implications of corporate mergers and acquisitions and consults with clients and their lobbyists on pending state tax legislation and regulations.

With nearly 30 years of experience in state tax, David brings to his clients an extensive knowledge of state tax law, strong relationships with state revenue departments, a track record of successfully litigating state tax cases and a deep understanding of procedural and strategic aspects of handling complex state tax audits and appeals. David has extensive experience in all areas of state taxation including state corporate income, sales and use, personal income, utility, insurance company and realty transfer taxes. He also advises clients on tax incentives, unclaimed property and unemployment compensation issues. David has handled audits, administrative appeals and litigation across the country and in states including New Jersey, New York, Pennsylvania, Massachusetts, Connecticut, Maryland, Delaware, New Hampshire and Rhode Island.

David is a frequent national speaker on multistate tax topics for many organizations, including the Council on State Taxation, the New York University Institute on State and Local Taxation, the Institute of Professionals in Taxation, the Tax Executives Institute, the Practicing Law Institute, the Georgetown Advanced State and Local Tax Institute, the Wall Street Tax Association – State and Local Tax Committee, the Pennsylvania Bar Institute, the New Jersey State Bar Association, the New Jersey Society of Certified Public Accountants and the New York State Society of Certified Public Accountants.

David is a member of the American Bar Association’s State and Local Tax Committee, a member of the advisory board for the New York University Institute on State and Local Taxation, a founding committee member for the Institute for Professionals in Taxation’s Income Tax Schools and has served as a member of New Jersey’s Corporation Business Tax Study Committee. He also is a member of the New Jersey Chamber of Commerce’s and New Jersey Business and Industry Association’s Joint State Tax Committee and frequently contributes to those organization’s legislative and regulatory efforts.

Additionally, David has published state tax articles in State Tax Notes, the American Bar Association’s The State and Local Tax Lawyer and Commerce Clearing House’s State Tax Review and he is frequently contacted by news organizations to comment on emerging state tax issues.

 

Nicole M. Wooten, Esq._ Maynard Nexsen PC._myLawCLENicole M. Wooten, Esq.| Maynard Nexsen PC.

Nikki Wooten’s practice concentrates on state and local tax (SALT) consulting and litigation, alcohol licensing and compliance, and appellate matters.

As part of her SALT practice, Nikki provides clients with expansive insight on state and local tax issues gained from her extensive litigation and appellate experience as Senior Counsel with the South Carolina Department of Revenue. An experienced tax litigator, Nikki has tried dozens of tax cases before state trial courts and federal district court, and briefed and argued cases before state appellate courts and the Fourth Circuit Court of Appeals. Most recently, Nikki litigated the first cases in South Carolina related to combined unitary reporting as an alternative apportionment method, frequently referred to in the SALT practice as “Forced Combination.” In addition, Nikki developed and litigated the preeminent cases in South Carolina addressing sourcing in the corporate income tax area. Nikki’s track record demonstrates her unique ability to successfully handle previously unlitigated issues for her clients. Similar to Nikki’s tax litigation experience, she has tried numerous cases related to alcohol licensing and compliance during her time at the Department of Revenue. Nikki also clerked and worked as a staff attorney with the South Carolina Administrative Law Court which allowed her to gain immeasurable experience in all administrative and regulatory matters.

Tapping into those unique and invaluable experiences, Nikki provides clients with comprehensive knowledge in the areas of corporate tax, bank tax, individual income tax, sales and use tax, admissions tax, withholding tax, property tax, tobacco tax, and regulatory licensing and compliance matters.

Nikki completed her undergraduate and law degrees at the University of South Carolina. She also earned an LL.M. in Taxation from the University of Alabama.

 

Michael J. Hilkin, Esq. _ McDermott Will & Emery_myLawCLEMichael J. Hilkin, Esq. | McDermott Will & Emery

Michael J. Hilkin represents clients in all aspects of complex state and local tax matters. He has a particular focus on tax controversy and transactional issues relating to state and local income, franchise, sales and use, gross receipts and other business taxes. Michael has extensive experience handling state and local tax issues before US administrative and judicial systems.

 

Dana Lance, CPA _ Grant Thornton_myLawCLEDana Lance, CPA | Grant Thornton

Dana Lance is the Tax Practice Leader for the Greater Bay Area and the SALT Practice Leader for the West Region. Dana is based in San Jose, California.

Dana has in-depth experience in providing a wide range of tax advisory services to businesses operating in a number of industries, but focuses primarily on technology, media and entertainment. Dana’s practice concentrations include: state tax minimization services including assisting taxpayers with the development and design of effective state tax planning; state due diligence reviews and M%26A transaction analysis and consulting; nexus reviews; voluntary disclosure agreement negotiations to minimize state tax exposures; accounting for income taxes and uncertain tax positions for both federal and state taxes; and compliance outsourcing and reviews.

 

Eric M. Anderson, Esq_Andersen Tax_myLawCLEEric M. Anderson, Esq. | Andersen Tax

Eric Anderson provides state and local tax services as part of the US National Tax practice. He has expertise in strategic tax planning, controversy representation, and tax risk management for clients across the firm. Eric also focuses on income tax planning and compliance, sales and use tax transaction planning, mergers and acquisitions, local tax matters, and administrative tax controversies.

Eric also has extensive experience with unitary tax planning, business and non-business issues, and entity structuring to manage multistate tax liabilities.

Eric serves as an Andersen firm-wide resource for credit and incentive consulting, including negotiated incentives related to company expansions and training activities, as well as statutory tax credits. He has helped clients obtain refunds for a variety of statutory credits aggregating millions of dollars.

Eric has practiced in the state and local tax area since 1994. Before joining Andersen, he worked with international professional services firms consulting in a variety of state and local tax areas. He also held a tax planning position with a Global 100 technology consulting corporation, where his team led a global reorganization to place the company in a tax efficient structure leading up to an initial public offering.

Eric serves as an adjunct professor with the University of San Francisco School of Law. He previously taught state and local taxation in other law programs. He is also a frequent speaker at national and regional conferences.

 

Michael J. Semes, Esq_BakerHostetler_myLawCLEMichael J. Semes, Esq. | BakerHostetler

Mike utilizes over 30 years of government executive, financial and academic experience to drive state and local tax value to his clients in their most significant controversies and transactions.

Mike has served as Pennsylvania Governor Tom Ridge’s Chief Tax Counsel, has been a partner in two ‘Big 4’ firms and is currently a professor of practice at Villanova University Law School Graduate Tax Program. This diverse background enables collaboration with his clients to examine various issues through legal, regulatory, policy, procedural, financial, reputational and academic lenses, leading to practical, goal-oriented solutions.

Mike has handled a broad range of tax issues and won significant victories in many state forums. From a sector perspective, he has a wealth of experience working with companies on both the regulated and non-regulated sides of the energy industry. Mike has also been actively involved in following, writing and speaking about the recent trends in adopting and proposing digital advertising taxes.

 

Ali R. Vahdat, Esq. _ Ernst & Young_myLawCLEAli R. Vahdat, Esq. | Ernst & Young

Ali has specialized in state and local tax for over 20 years and has provided tax advice to many corporations doing business in the following industries: consumer products, media and entertainment, real estate and investment companies, technology and communications.

His primary focus is state corporate income/franchise taxes.

Ali completed a rotation in our National State and Local Tax practice in Washington, DC, and has spoken at various forums, including the Georgetown University Law Center’s Advanced State and Local Tax Institute and the Tax Executives Institute.

Ali was an adjunct professor at Golden Gate University, teaching Multistate Taxation.

He received a BS in Business Administration from the University of California at Berkeley and a JD from the University of California College of Law, San Francisco.

 

Bruce J. Fort, Esq. | Multistate Tax Commission

Bruce J. Fort is senior counsel to the Multistate Tax Commission, a position he has held since 2007. Mr. Fort has co-authored numerous briefs filed with the U.S. Supreme Court and state appellate courts on matters affecting state taxation and federalism. Mr. Fort regularly leads state and local tax training programs for state revenue departments and attorneys general, and has advised numerous state tax agencies and legislative bodies on litigation and policy matters. Mr. Fort has served as principal staffer or hearing officer for several proposed uniform statutes and regulations promulgated by the Commission, and assisted in the Commission’s efforts to reform Compact Article IV (UDITPA). Mr. Fort is a frequent presenter at state and local tax conferences, including the Paul J. Hartman SALT Forum, the Georgetown University SALT conference, the American Bar Association Tax Section and the Tax Executives Institute training courses. He received a B.A. degree in history from the University of Oregon and his J.D. from the University of Oregon School of Law some years ago.

Prior to joining the Commission in 2007, Mr. Fort was a staff attorney and Special Assistant Attorney General with the New Mexico Taxation and Revenue Department for 16 years, where he served as lead counsel in many of the state’s gross receipts tax, corporate income tax and nexus cases. Mr. Fort began his legal career as a trial attorney with a firm in Santa Fe, New Mexico, where he continues to reside.

 

Alysse McLoughlin, Esq._ Jones Walker_myLawCLEAlysse McLoughlin, Esq. | Jones Walker

Alysse provides broad-ranging state and local tax counsel to clients across the country. With years of experience in private practice, as in-house tax counsel at leading financial institutions, and as an attorney in the Chief Counsel Division of the Internal Revenue Service, she understands the goals and priorities of businesses and tax authorities. Alysse draws on this knowledge to help clients make effective tax-planning decisions and resolve tax disputes.

Alysse advises on multistate tax matters, with an emphasis on New York and New Jersey issues. She has represented airlines, media and entertainment companies, banks and financial institutions, and other taxpayers before the New York State Tax Appeals Tribunal and the New York Appellate Division with respect to corporate income tax, insurance tax, bank tax, and sales tax issues. She has represented pharmaceutical companies, utilities, and other clients in New Jersey courts.

Alysse served as head of state tax for Barclays Capital, where she oversaw all state tax matters, including income, sales and use, franchise, excise, and other tax issues. Among other responsibilities, she established the company’s tax-return filing positions and reserves, participated in the development of financial statements and reports, consulted on the structuring of commodity transactions, and responded to audits conducted by state tax authorities. Prior to joining Barclays and after leaving the IRS, Alysse was state tax counsel for Lehman Brothers.

 

Jeffrey A. Friedman, Esq._ Eversheds Sutherland_myLawCLEJeffrey A. Friedman, Esq. | Eversheds Sutherland US

Honored as a 2022 Law360 MVP, Jeff Friedman provides sophisticated state and local tax planning, strategic advice and advocacy to numerous Fortune 100 and industry-leading companies. His comprehensive practice includes state and local tax planning, compliance, legislation and policy, and litigation and controversy matters involving income, franchise, sales and use and property taxes. Jeff’s clients span a variety of industries, including e-commerce, energy, technology and telecommunications.

A recognized thought leader on state and local tax issues, Jeff works on high-profile and precedent-setting litigation and controversy matters across the country. These matters impact critical questions on nexus, apportionment, the Multistate Tax Compact and the equal protection, due process and commerce clauses of the United States Constitution. Jeff is also a well-respected advocate on issues of tax policy, including the taxation of digital economy transactions.

Prior to joining Eversheds Sutherland (US), Jeff was a partner in KPMG’s Washington national tax practice; served as an attorney-adviser in the U.S. Department of the Treasury’s Office of Tax Policy, where he assisted with the development of the U.S. government’s position on domestic and international electronic commerce tax issues; and served as vice president and counsel of the Committee (now Council) On State Taxation (COST).

 

Richard D. Pomp, Esq._ University of Connecticut_myLawCLERichard D. Pomp, Esq. | University of Connecticut

Richard D. Pomp is the Alva P. Loiselle Professor of Law. He is a summa cum laude graduate of the University of Michigan and a magna cum laude graduate of Harvard Law School. He has taught at Harvard, New York University, Columbia, University of Texas, and Boston College. In addition, he has been a Distinguished Professor in Residence, Chulalongkorn Law School, Bangkok, Thailand, and a Visiting Scholar at the University of Tokyo Law School and at Harvard Law School.

Professor Pomp has been qualified as an expert witness in more than 30 states and the federal district courts and has appeared in more than 120 cases. He serves as counsel and a litigation consultant to law firms, corporations, accounting firms, and state tax administrations. He has participated in various capacities in U.S. Supreme Court litigation.

Professor Pomp has also served as a consultant to cities, states, the Multistate Tax Commission, the Navajo Nation, the U.S. Congress, the U.S. Treasury, the Department of Justice, the IRS, the United Nations, the IMF, the World Bank, and numerous foreign countries, including the People’s Republic of China, the Republic of China, Indonesia, the Gambia, Zambia, Mexico, the Philippines, Pakistan, India, and Vietnam. He is the former Director of the New York Tax Study Commission. Under his tenure, New York restructured its personal and corporate income taxes, and created an independent tax court.

Professor Pomp’s casebook, State and Local Taxation, now in its 9th edition, has been used in more than 100 schools, state tax administrations, and major accounting firms for their internal training. Portions of the casebook have been translated into Chinese, Dutch, German, Japanese, Spanish, and Vietnamese. He is also the author of more than 110 articles, numerous chapters in books, and various books and monographs. His writings have appeared in The New York Times, The Wall Street Journal, and the Financial Times.

In addition to the local and regional media, Professor Pomp has been interviewed by CNN, NPR, Bloomberg Radio, Sirius Radio, KCBS, WINA, The New York Times, The Wall Street Journal, The Washington Post, the Christian Science Monitor, the Los Angeles Times, the Minneapolis Star Tribune, the Sacramento Bee, The Baltimore Sun and The International Herald Tribune.

In 2007, he received the NYU Institute on State and Local Taxation Award for Outstanding Achievement in State and Local Taxation. In 2011, he was awarded the Bureau of National Affairs (BNA) Lifetime Achievement Award. He was the 2012 winner of the University of Connecticut’s Faculty Excellence in Teaching – Graduate Level. Tax Analysts selected him as its 2013 State Tax Lawyer and Academic of the Year. In 2014, he received the Council on State Taxation’s Excellence in State Taxation Award. The Connecticut Law Tribune selected him for a 2015 Professional Excellence Award. In 2017, he won the Perry Zirkel ’76 Distinguished Teaching Award. In 2022, he was appointed a Board of Trustees Distinguished Professor, the highest honor the University can bestow on a faculty member.

 

Lindsay LaCava, Esq._ Baker McKenzie_myLawCLELindsay LaCava, Esq. |Baker McKenzie

Lindsay M. LaCava is a Partner of the Firm’s Tax Practice Group in New York and is a member of the Firm’s Global Indirect Tax Steering Committee. Lindsay advises individual and business clients on a full range of state and local tax issues. She was ranked by Chambers in 2019 and 2020, was named a “Rising Star” in Tax Law in 2015 by Law360, has been recognized by International Tax Review in its “Women in Tax” Leaders Guide since 2016, and has been recognized by Super Lawyers as a New York-Metro “Rising Star” for Tax since 2013.

Prior to joining Baker McKenzie, Lindsay was a partner in the state and local tax group of an international law firm. In addition, she previously worked at a Big Four accounting firm, where her practice focused exclusively on state and local tax. Lindsay speaks on a variety of state tax topics at events around the country and also frequently writes about state and local tax issues, including serving as the former Managing Editor (State and Local Tax) for the American Bar Association’s “The Tax Lawyer,” co-authoring Bloomberg’s Connecticut Corporate Income Tax Navigator, and co-authoring Checkpoint Catalyst’s New York Corporate Franchise Tax guide. She also teaches State and Local Tax as an adjunct professor at Quinnipiac University School of Law.

 

Aliza L. Sherman, Esq. _ Stevens & Lee_myLawCLEAliza L. Sherman, Esq. | Stevens & Lee

Aliza represents clients in a variety of state tax matters, including corporate income, franchise, sales and use, realty transfer and personal income taxes. Her experience from working in accounting firms, as in-house counsel and as an attorney handling complex state tax litigation provides her with a comprehensive perspective to handling state tax matters. Aliza assists clients with state tax audits, administrative appeals and, when necessary, litigation. She has represented clients in state tax controversy matters before the New Jersey Tax Court, New Jersey Appellate Division, New York Division of Tax Appeals and Tax Appeals Tribunal, New York Appellate Division, Pennsylvania Board of Appeals and Board of Finance and Revenue and Massachusetts Appellate Tax Board. Aliza also provides clients with advice regarding the state tax implications of their everyday business operations as well as mergers and acquisitions.

Aliza served as a pro bono attorney for six years with Partners for Women and Justice, a nonprofit public law firm providing legal representation, advice and legislative advocacy that furthers positive change in the lives of domestic violence and sexual assault victims.

 

Chris Barber, Esq. _ Multistate Tax Commission_myLawCLEChris Barber, Esq. | Multistate Tax Commission

Counsel, Multistate Tax Commission, Dallas, TX

 

 

Dale Y. Dale Y. Kim, CPA _ Ernst Young LLP._myLawCLE, CPA | Ernst Young LLP.

Dale Young Kim, CPA is an IRS registered tax preparer in New York, New York. Dale Young Kim is associated with Ernst & Young LLP. If you are a taxpayer or a small business owner and looking for some assistance in tax filing preparation then Dale Young Kim can be of assistance to you.

 

Kelvin M. Lawrence, Esq._ Dinsmore & Shohl_myLawCLEKelvin M. Lawrence, Esq. | Dinsmore & Shohl

Kelvin is a business and tax lawyer who saves clients money by minimizing their tax exposure and finding solutions to their Ohio and multi-state tax issues. He advises on taxes implicated in multi-state transactions and has resolved Ohio state income tax, sales tax, commercial activity tax, pass-through entity tax, municipal income tax, and property tax appeals. Kelvin helps his clients manage interactions with taxing authorities and get the most from the involvement of expert witnesses and consultants in tax and unclaimed property audits and controversies. He has secured significant refunds in Ohio sales tax proceedings, as well as in real property tax exemption and valuation disputes. Kelvin has helped tax-exempt organizations obtain and preserve federal tax-exempt status by advising them on joint ventures, combinations, restructuring, compensation procedures, charitable activities, and financial assistance policies. He has also helped these organizations receive tax-exempt bond financing.

 

Ted W. Friedman, Esq. _ Eversheds Sutherland US_myLawCLETed W. Friedman, Esq. | Eversheds Sutherland US

Ted Friedman, a member of Eversheds Sutherland (US)’s Tax Practice Group, focuses his practice on state and local tax matters. Ted counsels clients on a wide range of state and local tax issues involving income and franchise taxes, sales and use taxes, gross receipts taxes, property taxes and telecommunication taxes. Ted represents clients in tax controversy, planning, policy and compliance matters.

Prior to joining Eversheds Sutherland (US), Ted worked in New York as an associate in the state and local tax group of an international law firm.

 

Jack Trachtenberg, Esq. _ Deloitte Tax_myLawCLEJack Trachtenberg, Esq. | Deloitte Tax

Jack Trachtenberg is a Principal in Deloitte’s Multistate Tax Controversy Services team in New York. Jack focuses on all aspects of state and local tax controversy matters for corporations and passthroughs, including income/franchise and sales and use tax, and has deep experience serving high-net-worth individuals in personal income tax matters, including residency.

Jack has extensive experience advising clients on New York State and New York City tax matters, having successfully litigated cases before the New York State Division of Tax Appeals, the New York State Tax Appeals Tribunal and the New York State Supreme Courts. Before joining Deloitte, Jack was a partner in the state tax practice at Reed Smith LLP. In 2009, the Governor of New York appointed Jack to serve as the first Deputy Commissioner and Taxpayer Rights Advocate at the New York State Department of Taxation and Finance. In this role, Jack created and implemented the state’s Office of the Taxpayer Rights Advocate, which intervenes on behalf of taxpayers facing intractable tax disputes.

Jack is a frequent speaker on state tax issues. Jack is also an author, editor, co-author or publisher of many publications, including the “Multistate Corporate Tax Guide,” the “Multistate Guide to Sales and Use Tax,” the “New York State Sales and Use Tax Answer Book,” and the LexisNexis “Tax Practice Insights: New York.” He is also a frequent contributor to tax and accounting publications, such as State Tax Notes and The CPA Journal, and has taught State and Local Tax courses at Albany Law School.

Jack holds a master’s and bachelor’s degree in political science from Case Western Reserve University and a Juris Doctor from the University at Buffalo School of Law.

 

Richard C. Call, Esq. _ McDermott Will & Emery_myLawCLERichard C. Call, Esq. | McDermott Will & Emery

Richard C. Call focuses his practice on all types of state and local tax matters including litigation, advisory, and transactional work. He has participated in successful cases at administrative bodies, trial courts, and appellate courts in several states. In 2020, he successfully argued before the Appeals Court of Massachusetts in Bay State Gas Company v. Commissioner, securing a rare reversal of the Massachusetts Appellate Tax Board in a corporate income tax case. Admitted to practice in both Massachusetts and New York, he has been recognized as a Super Lawyers, Rising Star in both Massachusetts and New York.

 

Harley T. Duncan _ KPMG_myLawCLEHarley T. Duncan | KPMG

30 years experience in state and local tax policy and tax administration. Keen understanding of state tax law and structure as well as the intersections between tax policy and tax administration, policy and the economy, and politics and policy. Skilled at resolution of tax controversies.

 

Federation of Tax Administrators_Logo_myLawCLEBrian L. Oliner, Esq. | Federation of Tax Administrators

 

 

 

Justin Pierce Berutich, Esq. _ Transactional_myLawCLEJustin Pierce Berutich, Esq. | Transactional

Justin Pierce Berutich is a Managing Director and Head of Tax at Euclid Transactional, where he is responsible for leading Euclid’s tax insurance practice and developing bespoke, commercial solutions to diverse tax matters.

A former M&A and transactional tax attorney, Justin enhances client value through the promotion and underwriting of tax indemnity insurance solutions. His corporate, tax, and insurance experience allows Justin to bring a unique perspective to each matter. Prior to joining the insurance world, Justin, a licensed attorney in three states and the District of Columbia, facilitated efficient and timely negotiations, planning, and structuring for Fortune 500 companies and high growth businesses, providing tax and business-centric advice to help his clients achieve objectives and avoid costly disputes.

Justin is a frequent speaker at industry events and on tax focused podcasts and has published multiple articles on tax and tax insurance. He holds an LL.M. in taxation from the NYU School of Law, a J.D., magna cum laude, from New York Law School, and a B.A., magna cum laude, in chemistry from Florida Atlantic University.

 

Tov Haueisen, Esq. _ PwC US_myLawCLETov Haueisen, Esq. | PwC US

Tov leads PwC’s Growth, Strategy, and Business Development for the Tax practice in addition to leading the New York Metro State and Local Tax practice. Tov works with his clients in all facets of state and local tax including income/franchise, sales/use, credits & incentives, AUP, and employment tax in the areas of controversy, planning, compliance, and M&A.

Tov is the lead state tax partner on a variety of Fortune 500 clients. He looks to help companies identify state tax opportunities that are consistent with the overall business objectives.

 

Jenny Wong, Esq. _ Ryan Transactional Risk_myLawCLEJenny Wong, Esq. | Ryan Transactional Risk

Jenny is an attorney and a member of the New York Bar. Jenny has over 19 years of U.S. tax experience. With concentrations in mergers, acquisitions, banking, financial products and insurance company taxation, Jenny worked in roles as an external tax advisor (for the Banking, Capital Markets and Insurance practice at PwC where she specialized in serving insurance, private equity and other financial institutions clients), as in-house tax attorney (for JPMorgan, AIG, Barclays, HSBC and Enstar Group), and as a junior structurer on Lehman Brothers’ trading desk. She received her J.D. from University of Pittsburgh and her LL.M in Taxation from New York University. Jenny joined the tax insurance industry in 2020 as an insurance broker and led the tax insurance practice at Atlantic Global Risk, joining Ryan Transactional Risk in 2023.

 

Jackie C. Orea _ Andersen Tax_myLawCLEJackie C. Orea | Andersen Tax

Jackie Orea has over 17 years of experience in delivering tax services to public and private corporate enterprises. As a member of Andersen’s State and Local Tax group, Jackie specializes in the sales /use tax and credits and incentives area. She has assisted clients with various multi-state sales use tax and property tax issues including audit defense, compliance, restructuring projects and consulting on various transactions. Jackie manages the tax function for clients without an internal tax department. She has assisted clients in obtaining refunds for a variety of statutory credits aggregating millions of dollars and obtained training grants. While she now focuses primarily on sales /use tax and credits and incentives, Jackie also assists clients on their multistate corporate tax income/franchise tax issues.

 

Jennifer S. White, Esq. _ Reed Smith_myLawCLEJennifer S. White, Esq. | Reed Smith

Jennifer is a partner in Reed Smith’s New York office. She works with companies and individuals to assist in reducing state tax liabilities and to eliminate risk of audit exposure. Jennifer’s practice focuses on New York State and City, New Jersey, and Connecticut issues. She excels at providing effective and practical counsel that meets the unique goals of each client. Through years of work in private practice and time spent with the New York City Department of Finance, Jennifer has learned the most effective strategies to both settle and litigate cases, and most importantly, when to pursue each avenue of resolution.

 

Kimberley A. Wick, CPA _ KPMG_myLawCLEKimberley A. Wick, CPA | KPMG

Kim Wick leads KPMG’s national Indirect Tax Compliance practice in the United States. In this role, she is responsible for managing KPMG’s U.S. Indirect Tax compliance centers located in Chicago and Atlanta. Kim previously led KPMG’s Pennsylvania business unit U.S. Indirect Tax for the State and Local Tax practice. She has more than 30 years of sales and transaction tax experience in public accounting, private industry, and government and she focuses on all aspects of sales and transactions tax transformation and technology, tax planning, and indirect tax compliance.

 

Amanda Hiller, Esq._myLawCLEAmanda Hiller, Esq. | New York State Department of Taxation and Finance

Amanda Hiller began serving as Acting Tax Commissioner on April 23, 2021. She continues in her role as General Counsel, a position she has held since December 2012.

As Acting Commissioner, she directs the activities of more than 3,700 employees whose mission is to efficiently collect tax revenues in support of state services and programs while acting with integrity and fairness in the administration of tax laws. Toward that end, the department promulgates tax regulations; publishes forms, instructions, and guidance; engages in taxpayer outreach and education; processes tax returns; resolves filing errors and taxpayer protests; conducts audits; engages in civil and criminal enforcement activities; litigates tax disputes; and manages the state treasury.

As General Counsel, she is responsible for legal policy and matters of law for the department. She oversees the Office of Counsel, which provides legal services for the department. These services include litigation; internal and external Tax Law advice; the preparation and review of legislation; and other administrative matters.

Over a 30-year career in public service, Amanda has held senior positions in the legislative, judicial and executive branches, as well as in the nonprofit sector.

She earned her law degree from Albany Law School and a bachelor’s degree from the State University of New York at Oswego.

 

Marita R. Sciarrotta, MPA _ Trenton_myLawCLEMarita R. Sciarrotta, MPA | Trenton

Marita R. Sciarrotta, a 40-year career public servant, was sworn in as Acting Director of the New Jersey Division of Taxation on September 25, 2023.

Marita’s working history with the Division of Taxation started during high school, and continued throughout college and after graduation from what is now The College of New Jersey. Her deep fascination with tax law and administration transformed a part-time job into a decades-long career in public service with practical experience in Local Property Tax Administration, Audit Activity, Conference and Appeals, Investigations, Collection, and training and mentoring new employees.

As a Deputy Director – her most recent role – she was tasked with oversight of the Collection & Enforcement, Data Systems and Taxpayer Services Activities.

Marita spent 20 years as an Investigator and manager in the Collection & Enforcement Activity, Compliance and Field Branches, before being promoted to State Executive Service as an Assistant Director of Taxpayer Services. She is a Subject Matter Expert in multiple tax types, has served as a spokesperson for the agency and participated in five tax amnesty programs.

 

John Biello, MPA_myLawCLEJohn Biello, MPA | Connecticut Department of Revenue Services

Currently serves as Connecticut’s Deputy Commissioner of Revenue Services (DRS), got the opportunity to fulfill his career aspiration when he assumed the role of Acting DRS Commissioner from January through December 2020.

 

Stephanie Anne Lipinski Galland, Esq | Miles Stockbridge

Stephanie Lipinski Galland has represented businesses before state and local taxing authorities in income, franchise, sales, use and unclaimed properties matters for more than 30 years.

Lipinski Galland advises businesses of all sizes and in all industries, from publicly traded to privately held, on issues such as tax and business planning and tax incentive negotiations and maintenance. She helps clients develop, implement and defend tax positions in state audits, as well as assists with mergers and acquisitions (including due diligence issues), administrative appeals, negotiated settlements and multistate voluntary disclosures. She also drafts and negotiates tax provisions in licensing agreements between brands and affiliated companies for both trademark and trade dress with unrelated parties for use of various trademarks.

She works with government contractors, developing responses to federal and state requests-for-proposals, subsequent modifications and appeals of terms and conditions. Lipinski Galland counsels contractors on compliance issues under the Federal Acquisition Regulation (FAR) and the Federal Acquisition Streamlining Act of 1994 (FASA) to ensure that the underlying contracts meet all necessary requirements.

Prior to entering private practice, Lipinski Galland worked as director of taxation for Gap Inc. and at the Virginia Department of Taxation. She serves as an adjunct professor at Georgetown University Law Center.

 

Burnet R. Maybank III, Esq. _ Nexsen Pruet_myLawCLEBurnet R. Maybank III, Esq. | Nexsen Pruet

For more than 40 years, my passion for growing South Carolina’s economy has never wavered. I assist local, regional, national, and international companies in understanding tax credits, laws, and economic development incentives available, parlaying my experience as a former two-time director of the Department of Revenue and as a tax attorney and economic development advisor.

 

Sharon R. Paxton, Esq. _ McNees Wallace & Nurick_myLawCLESharon R. Paxton, Esq. | McNees Wallace & Nurick

Sharon is vice-chair of the State and Local Tax Group.

She has more than 20 years of experience representing companies of all sizes in a broad range of state and local tax matters. Sharon assists clients in resolving disputes concerning sales and use tax, corporate net income tax, capital stock and franchise tax, fuel tax (IFTA), and business privilege tax liabilities. She also deals with some personal income tax matters for individuals. Sharon represents taxpayers in proceedings before the Board of Appeals, the Board of Finance and Revenue, the Commonwealth Court of Pennsylvania and the Pennsylvania Supreme Court. Additionally, she handles unclaimed property audit appeals and advises businesses concerning unclaimed property reporting obligations.

Sharon has extensive experience dealing with sales and use tax audit appeals and refund claims. She has obtained substantial relief for clients in cases involving diverse issues, ranging from audit procedures and documentation for nontaxable sales to the applicability of the manufacturing and public utility exclusions, the taxation of various types of services, and the taxation of items such as computer software, financial institution security equipment, and property transferred pursuant to construction contracts. Sharon also has considerable experience handling IFTA audit assessment appeals.

Sharon lectures on Pennsylvania tax topics for various organizations. She has written numerous articles on Pennsylvania tax topics and regularly publishes articles in the Pennsylvania Accountant.

 

Leah Robinson, Esq. _ Mayer Brown_myLawCLELeah Robinson, Esq. | Mayer Brown

Leah Robinson (formerly Leah Samit) leads Mayer Brown’s State & Local Tax group. A partner in the firm’s New York office, she advises public and private business entities on state and local tax planning, controversy and litigation.

In 2019, Leah was named to Law360’s inaugural list of “Influential Women in Tax Law,” which spotlights attorneys who have provided outstanding service to their clients and the public, while changing the dynamics at their workplace. She is ranked by Chambers USA 2021 in Band 2 for New York State and Local Tax.

Leah provides national and state tax strategy and audit assistance for clients on a full range of tax matters, including nexus, combination and apportionment, and net operating loss issues. Leah has argued tax cases at the trial court, appellate court, and
state supreme court levels, but is sensitive to most companies’ preference to resolve matters without litigation.

Leah regularly advises on the sales tax characterization of goods and services, with a particular focus on digital services and software as a service issues. Leah has drafted more than 15 articles on the taxation of online services and has presented on the topic at more than 30 conferences.

She is particularly well-known for her advocacy in New York City and New York State, as well as for advising on the impact of the massive New York tax reform undertaken in 2014 and 2015. She was appointed to the New York City Department of Finance Commissioner’s Advisory Board (2014–present) as well as to the city’s Pass-Through Taxation Working Group (2014–present), a think tank formed by the Department of Finance to assist with bringing reform to the city’s Unincorporated Business Tax. Leah has been a principal drafter of six reports issued by the New York State Bar Association Tax Section commenting on tax reform legislation and proposed draft regulations and one report issued by the New York City Bar Tax Section. She is the author of the “In a New York Minute” column published by State Tax Notes.

Leah is also well known for her advocacy in New Jersey tax disputes, covering income tax and sales tax matters. Leah was counsel or co-counsel in disputes related to invalidating New Jersey’s alternative minimum assessment (Stanislaus), addressing the now-defunct throwout rule (Pfizer), taxation of extraterritorial income (IBM), treatment of limited partners (Preserve II), taxation of partnerships (Pulte Homes), apportionment of income from securitized loan portfolios (Capital One), sales taxation of temporary help services (Labor Ready) and sales taxation of electricity distribution charges (Atlantic City Showboat). She has been appointed to the New Jersey Supreme Court Committee on the Tax Court (2017 to current, co-chairing the Committee in the 2019-2020 term) and authors the State Tax Notes column, “The Jersey Short—Everything You Need to Know about New Jersey Tax.”

Previously, as a tax lawyer with the IRS Office of Chief Counsel in New York City, she was part of the strategic trial team handling one of the largest section 482 transfer pricing controversies in history.

 

Jorge Rodriguez, Esq. | Rodriguez Law Firm

Education

LL.M. (Taxation), New York University School of Law
J.D., Georgetown Law Center
B.A., University of Rochester (Summa Cum Laude)

Admissions

New York State
District of Columbia
United States Supreme Court
United States Court of Appeals for the Second Circuit
United States Court of Appeals for the Ninth Circuit
United States District Court, Southern District of New York
United States District Court, Eastern District of New York
United States Tax Court

 

Timothy G. Schally, Esq._myLawCLETimothy G. Schally, Esq. | Michael Best & Friedrich, Milwaukee

Tim provides strategic counsel on tax matters contested by the Internal Revenue Service, the Wisconsin Department of Revenue, and the taxing authorities of other state and local jurisdictions. Contested matters, for Fortune 1000 and other clients, include:

• Federal income taxation of banks, insurance companies, and manufacturers
• Multistate apportionment and allocation of income
• Transfer pricing among affiliated entities
• Sales and use tax for retailers, manufacturers, and construction contractors

Tim has long been considered a “go-to” attorney on Wisconsin tax matters, both for out-of-state and Wisconsin-based companies. He regularly represents taxpayers with complex tax matters in administrative appeals, and in litigation before the Tax Appeals Commission and the Wisconsin appellate courts. It can be said that Tim “wrote the book” on Wisconsin taxes, as he is a principal author of The Complete Guide to Wisconsin Sales & Use Taxes, a treatise covering all aspects of the Wisconsin sales and use tax system, and the author of Wisconsin Business Taxes, an extensive examination of all Wisconsin business taxes.

 

Mark F. Sommer, Esq._myLawCLEMark F. Sommer, Esq. | Frost Brown Todd

With his local and national recognitions, Mark is a highly sought-after attorney resident in the firm’s Louisville office where he leads the firm’s Tax, Benefits and Estates Practice Group and practices in the areas of state, local and federal tax, tax controversy and litigation, and economic development/incentives.

In small matters as well as in “bet the company” situations, Mark has assisted his clients in avoiding hundreds and hundreds of millions of dollars in improperly asserted tax obligations and securing hundreds of millions in refunds and credits. His successes have lead to a national reputation as a practitioner and as a thought leader in State Taxation. He is a go-to advisor on State and Local Taxes in this part of the Country. With nearly 35 years of private practice experience, Mark has on a local, regional and national level successfully counseled and advocated in well more than a thousand federal, state and local tax matters, cases and planning/transactions involving multiple types of businesses, entities, trusts and individual taxpayers. He has also represented more than 110 members of the past and present Fortune 500.

Applying creativity, experience and work ethic, Mark serves his clients daily on all elements of state, local and federal taxation as well as civil/criminal tax controversy/litigation, business law, gaming law, economic development and incentives, tax-related governmental relations and bankruptcy taxation, with significant experience in the manufacturing space, and the automotive and maritime industries.

As a thought leader on taxation, over the years Mark has moderated, presented or spoken at more than 275 seminars and conferences sponsored by various organizations, including the Council on State Taxation, American, Kentucky and Louisville Bar Associations, Institute for Professionals in Taxation, Hartman SALT Forum, Southeastern Association of Tax Administrators, NYU Advanced SALT Conference, TEI and many more organizations.

 

Josh Veith, Esq. _ Ryan Law_myLawCLEJosh Veith, Esq. | Ryan Law

PROFESSIONAL EXPERIENCE

CURRENT
Attorney, Ryan Law

PREVIOUS
Judicial Clerk to President Judge Mary Hannah Leavitt of the
Commonwealth Court of Pennsylvania

 

Geoffrey Way, Esq. _ KPMG_myLawCLEGeoffrey Way, Esq. | KPMG

Director, KPMG, Sacramento, CA

 

 

Masha M. Yevzelman, Esq._myLawCLEMasha M. Yevzelman, Esq. | Fredrickson & Byron

Masha chairs Fredrikson’s Tax Disputes & Litigation Group. She represents public and private companies, trusts, estates and high-net-worth individuals in complex tax disputes. She handles all stages of tax controversies—voluntary disclosures, audits, administrative appeals, tax court, district court and appellate litigation.

 

Jaye A. Calhoun, Esq._myLawCLEJaye A. Calhoun, Esq. | Partner, Kean Miller, New Orleans, LA

Jaye Calhoun is a partner in the New Orleans office of Kean Miller. She joined the firm in 2017 and practices in the tax group. Jaye provides clients with full-service tax representation covering federal, state, and local tax challenges and business opportunities. She has more than 25 years of experience and assists her clients with tax compliance and planning, guidance on the use of tax and business incentives, and represents clients in tax audits and controversies. She regularly represents clients in audits and administrative and judicial appeals before the IRS, the State of Louisiana Department of Revenue, and numerous local taxing authorities. Jaye is board certified by the Louisiana Board of Legal Specialization in both Taxation and in Estate Planning.

Jaye has been listed for over a decade as one of the Best Lawyers in America (2007-2024), and in Louisiana Super Lawyers (2007-2023). She is AV Preeminent-rated by Martindale-Hubbell. Jaye is listed among the top tax lawyers in the State of Louisiana by Chambers USA 2022-2023. She has been recognized by New Orleans City Business as a 2005 Woman of the Year and selected as a 2014 recipient of the Leadership in Law award. Jaye was recognized by New Orleans Magazine as a Top Lawyer in 2012, 2016 and 2020-2022. She was also recognized as a Top Woman Attorney by Louisiana Super Lawyers. She was elected as a Fellow of the American College of Tax Counsel (ACTC) in 2017 and she was accepted into the Fellows of the American Bar Foundation (ABF) in 2019. Jaye has been appointed to serve on the American Bar Association’s The Tax Lawyer Editorial Board for 2022-2023.

 

Karl A. Frieden, Esq._myLawCLEKarl A. Frieden, Esq. | Council On State Taxation

Karl Frieden is the Vice President and General Counsel of the Council On State Taxation (COST). COST has a membership of nearly 600 multistate companies and is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of multi-jurisdictional entities. Prior to joining COST, Karl was a state and local tax partner with Ernst & Young and before that a tax partner with Arthur Andersen. Earlier in his career, he was the Deputy General Counsel of the Massachusetts Department of Revenue. Karl has had extensive experience with most types of state and local taxes including income tax, sales tax, property tax, payroll tax and credits and incentives.

He has also significant experience with global indirect taxes including VAT and withholding taxes. Karl has spoken on state and local and global indirect tax issues at business, academic and tax policy forums in the US, Europe and Asia. He has testified before state legislatures and the US Congress on state tax policy issues. He is author of numerous articles on state and local taxation; and wrote the book, Cybertaxation: The Taxation of E-Commerce (CCH 2000) – the first comprehensive book written on the taxation of the digital economy. Karl received his J.D. from Northeastern University School of Law, and his B.A. from the University of California, Berkeley.

 

Michael Garcia _ Ryan_myLawCLEMichael Garcia | Ryan

Principal, Ryan, Dallas – Three Galleria Tower office

Specializes in providing transaction tax services and audit management to retail, restaurant, fitness, software, and emerging industries, including renewable energy, urban farming, cryptocurrency mining, and blockchain.

Graduate, Leadership Development Program, Ryan

Includes 80+ hours of multidisciplined leadership training over a two-year period.

Agenda

DAY 1: MONDAY, DECEMBER 11

SPARE A SQUARE? – Moderator: Mitchell A. Newmark, Esq., Partner, Blank Rome, New York, NY, Michael J.Bryan, CPA, Deputy Director, Audit Activity, New Jersey Division of Taxation, Trenton, NJ, Robert M.Porcelli, Esq., Principal, PwC, Washington DC, David J. Shipley, Esq., Shareholder, Stevens & Lee,Princeton, NJ, Nicole M. Wooten, Esq., Of Counsel, Maynard Nexsen PC, Columbia, SC | 8:25am – 9:20am

Transfer Pricing SALT Controversies have increased over the years. States are concerned about possible abuse arising from inter-company transactions, while Taxpayers counter that the states have a plethora of other weapons to deploy (e.g., forced combination, addback statutes, alternative apportionment), in lieu of disputing established transfer pricing studies. What is your experience? Let’s discuss.

THERE ARE 2, NO 3, RESPONSIBLE TAXPAYERS IN EVERY SALES TRANSACTION – Moderator: Fred J. Nicely, Jr., Esq., Senior Tax Counsel, Council On State Taxation, Wooster, OH, Michael J. Hilkin, Esq., Counsel, McDermott Will & Emery, New York, NY, Dana Lance, CPA, National Managing Partner, SALT Solutions, Grant Thornton, San Jose, CA | 9:20am – 10:10am

The adoption of marketplace facilitator collection responsibilities has complicated sales tax reporting. While the “base case” of a small seller listing products for sale on a large marketplace appears straightforward, there are numerous less-than-obvious fact patterns, including when marketplaces sell on other marketplaces, seller “opt outs”, mere commission sales and foreign sellers. Is it time to address the inconsistent definition of “Marketplace Facilitator?”

Break | 10:10am – 10:25am

YOU CAN’T TOUCH THIS – TANGIBLE PERSONAL PROPERTY – IS IT PAST ITS PRIME? – Moderator: Marc A. Simonetti, Esq., Partner, State Tax Law, New York, NY, Eric M. Anderson, Esq., Managing Director, Andersen Tax, San Francisco, CA, Michael J. Semes, Esq., Of Counsel, BakerHostetler, Philadelphia, PA, Ali R. Vahdat, Esq., Americas Indirect and State & Local Tax Leader, EY, Los Angeles, CA | 10:25am – 11:15am

Tangible personal property has been a cornerstone concept for both income taxation and sales taxation. But recent court decisions have demonstrated the difficulty in defining this term. In light of the developments associated with efforts to the increasing digitalization of our economy – which has profound effects on sales taxability, income tax sourcing, and the application of Public Law 86-272, the speakers cover the inconsistent interpretations of tangible personal property. Or perhaps abandon the definition altogether?

BIG GAIN HUNTING – Moderator: Lynn Gandhi, Esq., Partner, Foley Lardner, Detroit, MI, Bruce J. Fort, Esq., Senior Counsel, Multistate Tax Commission, Washington, DC, Alysse McLoughlin, Esq., Partner, Jones Walker, New York, NY | 11:15am – 12:00pm

States’ treatment of non-recurring extraordinary gains continue to evolve, impacting both the determination of the tax base as well as apportionment factor considerations and the use of alternative apportionment. Further, gains from the sale of pass-through entity interests pose additional complications. This panel addresses recent decisions confronting the issues that arise from transactions that produce big gains (and losses).

Lunch | 12:00pm – 1:00pm

OVERVIEW AND PREVIEW OF FEDERAL CONSTITUTIONAL ISSUESJeffrey A. Friedman, Esq., Partner, Eversheds Sutherland US, Washington, DC, Richard D. Pomp, Esq., Professor of Law, University of Connecticut, Hartford, CT | 1:00pm – 2:00pm

Our commentators provide a spirited preview of the most significant constitutional cases in state taxation over the past year as well as a preview of important cases to watch in the coming year.

GOING LOCAL – Moderator: Nicole L. Johnson, Esq., Partner, Blank Rome, New York, NY, Lindsay LaCava, Esq., Partner, Baker McKenzie, New York, NY, Aliza L. Sherman, Esq., Of Counsel, Stevens & Lee, Elmwood Park, NJ | 2:00pm – 3:00pm

Local taxes are proliferating and can be challenging to learn, administer and challenge. Moreover, the disconnect from established state nexus standards and tax base definitions further complicate compliance. What do you know and need to know?

Break | 3:00pm – 3:15pm

JUST PASSING THROUGH – Moderator: Bruce P. Ely, Esq., Partner, Bradley Arant Boult Cummings, Birmingham, AL, Chris Barber, Esq., Counsel, Multistate Tax Commission, Dallas, TX, Dale Y. Kim, CPA, Partner, EY, New York, NY, Kelvin M. Lawrence, Esq., Partner, Dinsmore & Shohl, Columbus, OH | 3:15pm – 4:15pm

This panel provides the state of the states’ status of tax planning, compliance and controversies associated with ownership of multistate partnerships and LLCs. Coverage addresses the complexities arising from the new PTE tax regimes and combined reporting issues.


SO, NOW WHAT DO WE DO? ETHICAL CHALLENGES ASSOCIATED WITH TAX FILINGS
– Moderator: Glenn C. McCoy, Jr., CMI, Esq., Principal, Client Services, Ryan, New York, NY, Ted W. Friedman, Esq., Partner, Eversheds Sutherland US, New York, NY, Jack Trachtenberg, Esq., Principal, Deloitte Tax, New York, NY | 4:15pm – 5:15pm

Your client (or your colleagues) messed up a tax return, failed to timely file a return, or perhaps needs to correct a return previously filed. The speakers evaluate the options for fixing mistakes, and the practical opportunities to coming clean, resolving presentation issues, evaluating playing the audit lottery, as well as other options that will let you sleep easier at night.

DAY 2: TUESDAY, DECEMBER 12

WHAT’S ON THE HORIZON? – Moderator: Gregory S. Matson, Esq., Executive Director, Multistate Tax Commission, Washington, DC, Richard C. Call, Esq., Partner, McDermott Will & Emery, New York, NY, Harley T. Duncan, Consultant, KPMG, Washington, DC, Brian L. Oliner, Esq., General Counsel, Federation of Tax Administrators, Washington, DC | 8:30am – 9:25am

The one thing we know for sure is that SALT will continue to evolve. Will we see more gross receipts taxes? Digital advertising taxes? Will states continue to limit the applicability of P.L. 86-272? The speakers share their views on the most interesting and expected state and local tax changes over the next few years.

REST INSURED: THE PROS AND CONS OF INSURING STATE TAX POSITIONS AND CONTROVERSIES – Moderator: Matthew P. Hedstrom, Esq., Partner, Alston & Bird, New York, NY, Justin Pierce Berutich, Esq., Managing Director, Head of Tax, Euclid Transactional, New York, NY, Tov Haueisen, Esq., Partner, PwC US, New York, NY, Jenny Wong, Esq., Vice President & Counsel, Ryan Transactional Risk, New York, NY | 9:25am – 10:15am

What exactly is tax insurance, and what are the considerations to obtaining a policy? Considerations may vary between the insured (taxpayer) and the insurer. Hear about how insurance companies assess the insured’s return position/transaction/litigation position. In addition, what are the tax accounting considerations of the insured? There is more behind the curtain to learn.

Break | 10:15am – 10:30am

BEST PRACTICES IN SALES AND USE TAX COMPLIANCE – Moderator: Carolynn S. Kranz, Esq., Managing Member, Industry Sales Tax Solutions, Doylestown, PA, Jackie C. Orea, Managing Director, Andersen Tax, San Francisco, CA, Jennifer S. White, Esq., Partner, Reed Smith, New York, NY, Kimberley A. Wick, CPA, Principal, KPMG, Atlanta, GA | 10:30am – 11:20am

The use of shared service centers, AI, and other technologies have become the standard in sales and use tax compliance. This panel identifies the best practices that address the most common challenges, particularly those associated with defining and situsing taxable services, implementation and maintenance of complex tax matrices, and adherence to tax accounting rules.

THE TRI-STATE PANEL – Moderator: Richard W. Genetelli, CPA, Managing Director, Genetelli Consulting Group, New York, NY , Amanda Hiller, Esq., Acting Tax Commissioner and General Counsel, New York State Department of Taxation and Finance, Albany, NY (Invited), Marita R. Sciarrotta, MPA, Acting Director, New Jersey Division of Taxation, Trenton, NJ, John Biello, MPA, Deputy Commissioner, Connecticut Department of Revenue Services, Hartford, CT | 11:20am – 12:15pm

A lively discussion of current key topics by state tax officials from New York, New Jersey and Pennsylvania/Connecticut

Lunch | 12:15pm – 1:15pm

WHAT’S HAPPENING EVERYWHERE TODAY? – Moderators: Ginny Buckner Kissling, Global President and Chief Operating Officer, Ryan, Dallas, TX, Douglas L. Lindholm, Esq., Executive Director, Council On State Taxation, Washington, DC, David A. Hughes, Esq., Partner, HMB Legal Counsel, Chicago, IL, J. William McArthur, Jr., Esq., former VP Tax Planning, TE Connectivity, Berwyn, PA, SPECIAL REPORTERS: Stephanie Anne Lipinski Galland, Esq., Principal, Miles Stockbridge, Washington, DC , Burnet R. Maybank III, Esq., Member, Nexsen Pruet, Columbia, SC, Sharon R. Paxton, Esq., Of Counsel, McNees Wallace & Nurick, Harrisburg, PA, Leah Robinson, Esq., Partner, Mayer Brown, New York, NY , Jorge Rodriguez, Esq., Managing Principal, Rodriguez Law Firm, New York, NY, Timothy G. Schally, Esq., Partner, Tax Practice Group Chair, Michael Best & Friedrich, Milwaukee, WI, Mark F. Sommer, Esq., Member and Practice Group Leader, Frost Brown Todd, Louisville, KY, Josh Veith, Esq., Senior Attorney, Ryan Law, Austin, TX , Geoffrey Way, Esq., Director, KPMG, Sacramento, CA (Invited), Masha M. Yevzelman, Esq., Shareholder, Fredrickson & Byron, Minneapolis, MN, Jaye A. Calhoun, Esq., Partner, Kean Miller, New Orleans, LA , Karl A. Frieden, Esq., Vice President and General Counsel, Council On State Taxation, Washington, DC, PRODUCER: Michael Garcia, Director, Ryan, Dallas, TX | 1:15pm – 4:30pm

Get ready for a jam-packed show! It’s hard to cover the ever-changing state and local tax landscape, but an all-star team of “special reporters” provides a rundown of what you need to know about the most important SALT developments affecting taxpayers today. Then, stick around for “Meet the Press” and a panel discussion on important developments in the New York / New Jersey / Pennsylvania region.