Eversheds Sutherland’s SALT Team is a proud sponsor of the Georgetown Law 2018 Advanced State and Local Tax Institute taking place May 31 – June 1, 2018, in Washington, DC. Marc Simonetti presents, “Breakout B. Breakout the Income Taxes!” and Carley Roberts presents, “Is Alternative Apportionment the New Normal?” Eversheds Sutherland hosts and sponsors a welcome reception at our DC office from 6:00 – 7:30 p.m. Eastern standard time, on May 30, 2018.
Speakers and Panels Announced! TEI’s Audits and Appeals Seminar: State and Local Tax Controversy
For more than 25 years, the Tax Executives Institute (TEI) has met the tax controversy needs of the in-house professional community through its Audits & Appeals Seminar. Leading practitioners, regulators, policymakers and jurists join TEI annually to discuss the nuts, bolts and nuances of tax controversy.
Eversheds Sutherland is delighted to sponsor and lead the two days of the seminar focused on State and Local Tax Controversy (May 2 – 3, 2018), which includes the following sessions:
Wednesday, May 2
- Managing State Tax Filings and Audits
Speakers: Jeff Friedman and Andrew Appleby - Challenging Assessments and Filing Protests
Speakers: Michele Borens and Eric Coffill - Protest Workshop – Breakout and Regroup
Speakers: Carley Roberts and Scott Wright
- Coordinating Multistate Controversies
Speakers: Eric Tresh and Maria Todorova
- Industry Panel
Moderator: Jeff Friedman
Thursday, May 3
- Resolution Through the Courts
Speakers: Tim Gustafson and Carley Roberts
- Perspectives from the Other Side – State Tax Attorney Panel
- Moderator: Pilar Mata, Tax Executives Institute
- Ray Langenberg, Special Counsel for Tax Litigation, Texas Comptroller of Public Accounts
- Christine Mesirow, Chief, Taxation Section, Ohio Attorney General’s Office
- Brian Oliner, Assistant Attorney General/Principal Counsel, State of Maryland
- Innovative Uses of Technology in Tax Controversies (with tech vendors)
Speakers: Charlie Kearns
- State Tax Considerations Everyone Should Know About
Moderator: Andrew Appleby and Jonathan Feldman
- All Rise – A View from the Bench
- Moderator: Richard Pomp, University of Connecticut School of Law
- Martha Blood Wentworth, Judge, Indiana Tax Court
- Douglas Bramhall, Administrative Law Judge, California Office of Tax Appeals
- Cade Cole, Vice-Chairman, Louisiana Board of Tax Appeals
The program will take place April 30 – May 3 in New Orleans, Louisiana:
- April 30 – May 1: Federal Tax Controversy
- May 2: Transfer Pricing Controversy
- May 2 – 3: State and Local Tax Controversy, sponsored by Eversheds Sutherland
Eversheds Sutherland also invites attendees to join us for a reception at House of Blues New Orleans the evening of Wednesday, May 2. Join us and register for TEI’s Audits & Appeals Seminar today!
Click here for event details and registration information.
Submit your pet to be featured as the April SALT Pet of the Month!
The Eversheds Sutherland SALT Team is always excited to see what kind of pets our clients and friends have. Our team features a different pet at the end of every month, and we want to feature YOURS! Featured pets will receive a fun prize from the SALT Team. The deadline for April submissions is Wednesday, April 25.
To submit your pet to be featured, visit the Eversheds Sutherland SALT Shaker App, click “Pet of the Month” in the drop-down, then click “Submit A Pet.”
Don’t have the app? It is available for download in the Apple App Store, Google Play and the Amazon Appstore.
Eversheds Sutherland SALT Shaker: March 2018 Digest
Read our March 2018 posts on stateandlocaltax.com or read each article by clicking on the title. For the latest coverage and commentary on state and local tax developments delivered directly to your phone, download the latest version of the Eversheds Sutherland SALT Shaker app.
- SALT Pets of the Month: Milo and Otis
Meet Milo and Otis, the five-month-old tabby cat brothers belonging to Eversheds Sutherland SALT Associate Jessica Allen and her husband Erik. - Georgia passes legislation to provide deduction of GILTI from the state tax base
On March 21, 2018, the Georgia Legislature passed SB 328 (the Bill) to exclude IRC § 951A (GILTI) from Georgia taxable income. The Bill treats GILTI as Subpart F income for purposes of the deduction under OCGA § 48-7-21(b)(8). - Idaho Enacts Corporate Income Tax Changes to Take Advantage of the Federal Tax Reform Legislation
On March 12, 2018, Idaho’s governor signed into law H.B. 463 (the Bill), which provides a series of changes to Idaho’s income tax law in response to H.R. 1, popularly referred to as the Federal Tax Cuts and Jobs Act (the Act). - Texas Rules Sales for Resale of Mobile Voice and Data Services are Not Sales of Intangible Assets for Apportionment Purposes
The Texas Comptroller ruled that, for Texas apportionment purposes, the sale for resale of mobile voice and data services, purchased from third-party mobile telecommunications carriers and sold to an out-of-state third-party retailer using the carrier’s network infrastructure, is characterized as the sale of telecommunications services and internet access services, respectively, not the sale of an intangible right to access a service.
FEATURED PUBLICATIONS
- Videocast: State Tax Implications of Federal Tax Reform
The state and local tax (SALT) implications of federal tax reform are numerous, yet still often unclear. With states releasing new law and guidance about federal tax reform, taxpayers must stay abreast of this very dynamic area of law. In this videocast, Todd Lard and Todd Betor discuss the gating question to the SALT implications of federal tax reform—state conformity to the IRC—along with other SALT considerations pertaining to major general, domestic and international tax provisions included in the new tax law. - California Seeks Input on Clean Energy Equipment Tax Exemption
During the second half of 2017, California expanded its partial sales and use tax manufacturing and research and development exemption to include electric generation and distribution equipment. The legislative changes are particularly favorable to businesses engaged in electric generation through the use of renewable energy sources. The California Department of Tax and Fee Administration (CDTFA) has issued a notice inviting stakeholders to participate in an interested parties meeting (IPM) scheduled for April 11, 2018, to discuss whether the CDTFA should undertake a regulatory project to amend its corresponding regulation to implement and apply the statutory changes and, if so, to what extent. In their article for Law360, Eversheds Sutherland attorneys Carley Roberts, Robert Merten and Jessica Allen summarize the sales and use tax exemption’s scope and qualifying requirements, the 2017 legislative changes to the exemption, the CDTFA’s proposed amendments and why stakeholders may want to participate in the IPM process. - Moving into Worldwide Waters? States Reaching Beyond the Water’s-Edge
Many states require or permit affiliated businesses to report their income to the state in a combined group return. In their article for Bloomberg Tax, Eversheds Sutherland attorneys Maria Todorova, Justin Brown and Samantha Trencs discuss some of the complexities of combined reporting related to the inclusion of foreign entities in a combined group, including trends among states intended to expand the combined group to include additional foreign affiliates. - Waiting for the Other Shoe to Drop: State and Local Tax Implications of Federal Tax Reform – International Tax Provisions
The state and local tax (SALT) impact of the recently enacted federal tax reform is still being assessed. Because of states’ broad conformity to the federal income tax laws, many of these changes will have an impact on taxpayers’ SALT liabilities. In their article for Bloomberg Tax, Eversheds Sutherland attorneys Jeff Friedman, Todd Betor and Michael Spencer focus on the SALT consequences stemming from international provisions of the Tax Cuts and Jobs Act.
FEATURED EVENTS
- TEI’s Audits and Appeals Seminar
Eversheds Sutherland is delighted to sponsor and lead the two days of the seminar focused on State and Local Tax Controversy (May 2-3, 2018) during TEI’s 2018 Audits & Appeals Seminar. We hope to see you there! - TEI’s 2018 Region II Forum
Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary and ten breakout sessions offering a wide selection of federal, international, and state and local topics. Register today and join us!
Register today for TEI’s 2018 Region II Tax Forum (June 4-5)
Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary and ten breakout sessions offering a wide selection of federal, international, and state and local topics.
The Eversheds Sutherland Tax Team presentations are listed below. Eversheds Sutherland will also sponsor the hospitality reception from 5:00 p.m. – 6:30 p.m. on June 4.
- US federal tax reform
ES Speaker: Partner Robb Chase - International implications of US tax reform
ES Speaker: Partner Aaron Payne - Tax considerations in restructuring and mergers and acquisitions
ES Speaker: Partner Taylor Kiessig - SALT implications of US tax reform
ES Speaker: Partner Marc Simonetti - IRS audit update
ES Speaker: Partner Jim Mastracchio - SALT considerations in restructuring and mergers and acquisitions
ES Speaker: Partner Maria Todorova - Partnership and joint venture update
ES Speaker: Partner Karl Zeswitz - SALT controversy and related business decisions
ES Speaker: Partner Andrew Appleby - Ethics
ES Speaker: Partner Vanessa Scott - International implications of US tax reform
ES Speaker: Partner Daniel Nicholas - Managing tax controversies – A global perspective
ES Speaker: Partner Susan Seabrook - State tax policy under the new US order
ES Speaker: Partner Todd Lard - Accounting methods and significant issues and tax-planning opportunities
ES Speaker: Partner Ellen McElroy - Financial reporting considerations post reform: The interplay of Section 451(b) and ASC 606
ES Speaker: Attorney Mike Resnick
View details and register now!
Notes:
- The $225 registration fee covers all of the technical sessions, breakfast, lunch and refreshments on both days, as well as our Monday evening reception.
- Breakfast, luncheons and the reception are open to spouses, guests and vendor-sponsors as well.
- To reserve your hotel room, use the Tax Executives On-Line Booking Link or call (609) 317-1000 and mention the TEI Conference Code GBTAX18
- Golf, casinos, transportation to the Boardwalk, spa and other activities are available at all times; arrangements can be made. Attendees will be responsible for fees/costs.
Videocast: State Tax Implications of Federal Tax Reform
The state and local tax (SALT) implications of federal tax reform are numerous, yet still often unclear. With states releasing new law and guidance about federal tax reform, taxpayers must stay abreast of this very dynamic area of law. In this videocast, Todd Lard and Todd Betor discuss the gating question to the SALT implications of federal tax reform—state conformity to the IRC—along with other SALT considerations pertaining to major general, domestic and international tax provisions included in the new tax law.
View the videocast.
Submit your pet to be featured as the March SALT Pet of the Month!
The Eversheds Sutherland SALT Team is always excited to see what kind of pets our clients and friends have. Our team features a different pet at the end of every month, and we want to feature YOURS! Featured pets will receive a fun prize from the SALT Team. The deadline for March submissions is Monday, March 26.
To submit your pet to be featured, visit the Eversheds Sutherland SALT Shaker App, click “Pet of the Month” in the drop-down, then click “Submit A Pet.”
Don’t have the app? It is available for download in the Apple App Store, Google Play and the Amazon Appstore.
TEI’s Audits & Appeals Seminar: State and Local Tax Controversy
For more than 25 years, The Tax Executives Institute has met the tax controversy needs of the in-house professional community through its Audits & Appeals Seminar. Leading practitioners, regulators, policymakers and jurists join TEI annually to discuss the nuts, bolts and nuances of tax controversy.
Eversheds Sutherland is delighted to sponsor and lead the two days of the seminar focused on State and Local Tax Controversy (May 2-3, 2018), which includes the following sessions:
- Panel presentations by state tax court judges, state attorney generals and industry professionals
- Comprehensive, in-depth examination of SALT controversies, including state tax filings, audits, protests and litigation
- Workshop addressing best practices in drafting state tax protests
- Using tax technology to manage tax controversies
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TEI’s Audits & Appeals Seminar will take place April 30-May 3, 2018, in New Orleans, Louisiana:
- April 30-May 1: Federal Tax Controversy
- May 2: Transfer Pricing Controversy
- May 2-3: State and Local Tax Controversy, sponsored by Eversheds Sutherland
Register for the seminar segments that best meet your tax controversy needs. In addition, all attendees will be able to submit questions anonymously through a secure TEI portal and have those questions addressed as part of the program.
View details and register now!
Register Now: TEI 68th Midyear Conference
Eversheds Sutherland is a proud Platinum Sponsor of the Tax Executives Institute (TEI) 68th Midyear Conference on March 25-28, 2018, in Washington, DC. The conference is held at the Grand Hyatt Hotel.
Eversheds Sutherland partners Jeffrey Friedman, Ellen McElroy, Maria Todorova, Susan Seabrook, Daniel Nicholas and attorney Jessica Eisenmenger present, and the details of their presentations are below.
As a Platinum Sponsor, Eversheds Sutherland hosts a reception for conference attendees Monday, March 26, 6:30-9:00 p.m. at the Grand Hyatt Washington, Constitution C, D, E.
Monday, March 26
11:30 a.m. – 12:30 p.m.
The New Revenue Recognition and Lease Accounting Standards – Practical Issues and Applications
Speaker: Ellen McElroy (Federal)
Tuesday, March 27
10:45 a.m. – 11:45 a.m.
IRS Appeals – New Faces, New Challenges
Speaker: Susan Seabrook (Insurance)
Tuesday, March 27
1:45 p.m. – 2:45 p.m.
State Tax Aspects of Cross Border Transactions
Speakers: Jeff Friedman and Maria Todorova (SALT)
Wednesday, March 28
8:30 a.m. – 9:45 a.m.
State and Local Issues in Contract Drafting
Speakers: Daniel Nicholas (Federal) and Jessica Eisenmenger (SALT)
Eversheds Sutherland SALT Shaker: February 2018 Digest
Read our February 2018 posts on stateandlocaltax.com or read each article by clicking on the title. For the latest coverage and commentary on state and local tax developments delivered directly to your phone, download the latest version of the Eversheds Sutherland SALT Shaker app.
- SALT Pet of the Month: Jinx
Meet Jinx, the two-year-old American Shorthair Tortoiseshell Calico kitty, submitted through our SALT Shaker App. This sweet girl and her brother, Cider, were adopted from Homeward Bound, a Portland, Oregon rescue. - How Will Georgia Conform to Federal Tax Reform? Annual Legislation Introduced
The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted federal tax reform, this year’s conformity bill will receive particular attention because of what tax reform provisions Georgia chooses to adopt and not to adopt. - Missing Proof, Protest Denied: Indiana Finds Throwback Proper Where Manufacturer Fails to Substantiate Taxability
The Indiana Department of State Revenue issued a Letter of Finding denying a taxpayer’s protest of throwback sales because the taxpayer failed to substantiate being subject to tax in multiple jurisdictions. - Detroit City Blues: Michigan Court of Appeals Holds Law Firm’s Services Excluded from Sales Factor Numerator
The Michigan Court of Appeals held that sales of a Detroit attorney’s services can be included in the sales factor numerator for the Detroit income tax only if the client received the services in Detroit. - ACMA Challenges Ohio’s Software and Network Nexus Provisions
The American Catalog Manufacturers Association (ACMA) filed an action for a declaratory judgment in Ohio state court asserting that the new Ohio statutory definition of substantial nexus, which was expanded to include remote sellers by adopting “software” and “network” nexus provisions, violates the Commerce Clause, the Due Process Clause and the Internet Tax Freedom Act (ITFA).
FEATURED PUBLICATIONS
- Videocast: SALT Scoreboard – 2017 Year in Review
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this videocast, Charles C. Capouet and Jessica N. Allen share 2017 year-end observations, including taxpayers’ performances in corporate income tax and sales and use tax cases and the Pennsylvania Supreme Court’s decision in Nextel. Stay tuned for upcoming 2018 editions of the Eversheds Sutherland SALT Scoreboard!