Sutherland and the Tax Executives Institute (TEI) are pleased to present this first ever full-day program dedicated to the “Theory, Strategy and Practice of State Tax Controversy” in San Francisco, California on May 21. Topics covered will include:

Understanding the State Tax Controversy Lifecycle
Best Practices for Preparing and Managing State Tax Audits
Best Practices for Protests and Litigation
Avoiding Career Limiting Mistakes: Monitoring Statutes of Limitation
Coordinating State and Federal Income Tax Audits
Sales and Use Tax Audit Trends
Corporate Income Tax Audit Trends
  • Understanding the State Tax Controversy Lifecycle
    • Managing litigation in multiple states
    • Strategic decisions surrounding multistate litigation
    • Effective use of counsel and consultants in multistate litigation
    • Choice of forum considerations
    • When to settle and when to appeal
    • Dollar settlements versus alternative methodologies
    • Timing, costs and tangential considerations for settlements
  • Best Practices for Preparing and Managing State Tax Audits
    • The importance of concurrent documentation and witnesses
    • Developing an audit work plan 
    • Tracking and responding to IDRs
    • Maintaining comprehensive audit files 
    • Managing MTC audits
  • Best Practices for Protests and Litigation
    • Requirements and state variations for protests
    • Skeletal protests versus comprehensive protests
    • Documenting and protecting alternative theories
    • Developing a trial plan
    • Discovery issues
    • Simplifying the case/alternatives to trial
  • Avoiding Career Limiting Mistakes: Monitoring Statutes of Limitation
    • Monitoring statutes of limitations 
    • Monitoring waivers
    • Protecting state attorney-client privileges, accountant-client privileges, and work product 
    • Use of consultants/experts
    • Best practices for managing files
  • Coordinating State and Federal Income Tax Audits
    • Coordinating the disclosure of information to the IRS and state tax authorities
    • Reporting federal changes to state tax authorities
    • The impact of federal reporting on state statutes of limitation
    • Coordinating state income and sales and use tax audits
  • Sales and Use Tax Audit Trends
    • Cloud computing issues
    • Attributional nexus
    • False claims actions
  • Corporate Income Tax Audit Trends
    • Alternative apportionment
    • Costs of performance versus market sourcing
    • MTC compact litigation

The State Tax Controversy Conference is presented in conjunction with TEI’s Audits and Appeals Conference on May 19-20. Attendees can choose to attend only the State Tax Controversy Conference or the entire Audits and Appeals Conference. To register or to learn more, please visit TEI’s website.