SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Corporate Tax
- event Date
Monday, June 16, 2025
- schedule Time
1:00 PM E.T.
- timer Program Length
110 minutes
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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.
Faculty

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.

Description
State tax collection initiatives on foreign and domestic business activities are as prevalent as business planning efforts on federal income and employment taxes. Selective add-backs, tax haven legislation, and combined reporting based on the unitary business approach, subjecting subsidiaries and affiliates or their income to state taxation, are the most aggressive approaches for states to increase revenues from foreign transactions and foreign corporations.
Recent changes to federal taxation raise conformity challenges for states, as well as constitutional limitations on the states' abilities to benefit from the federal changes. Knowledge of state tax legislation and tax planning methods are essential elements of corporate income tax compliance and reporting.
Listen as our panel discusses and provides an analysis of the impact of state tax legislation on foreign corporations, effective compliance procedures, business apportionment rules, and limiting multinational corporations' state reporting of business activities within the U.S.
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
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Determine an effective method of limiting exposure to state tax liability
- Identify critical aspects of state tax haven legislation
- Establish an effective method of state tax reporting procedures for foreign corporations
- Ascertain the methods available to reduce and limit state tax liability
- 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 at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, international taxation, state/local tax compliance, and acquisitions.

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.
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