BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Corporate Tax

Date & Time
  • event Date

    Thursday, October 24, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

$247.00
CPE
ALL

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.

Faculty

Jeffrey S. Reed
Partner
Kilpatrick Townsend & Stockton LLP

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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Michael J. Cataldo
Shareholder
Cataldo Tax Law, PC

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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Description

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 recently.

Outline

  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

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

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand top nexus/PL 86-272 cases and their application
  • Recognize business vs. non-business income
  • Identify advantages and requirements related to combined reporting
  • Discern how apportionment is made among the states
  • Recognize sales factor sourcing

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.