The Tax Executives Institute’s (TEI) State and Local Tax Committee is holding a series of State Tax Reform Roundtables to enable SALT professionals to stay abreast of state tax developments associated with the Tax Cuts and Jobs Act, to engage with subject-matter experts, and to hear from peers regarding their “boots on the ground” knowledge and experience.

This series of calls will create a platform for all members to learn, share and engage about issues of interest. Each call will highlight a particular topic and will provide a general update of state tax reform developments. Partners Jeff Friedman, Eric Tresh and Todd Lard will present on the roundtable calls, and details of their presentations are below.

IRC 965, BEAT, GILTI and FDII – Through the Lens of a SALT Professional + Recent Developments

June 21, 2018

Presenter: Jeff Friedman

Legislative Roundup – What are the States Doing + Recent Developments

July 19, 2018

Presenter: Eric Tresh

IRC Sec 118, Credits and Incentives – What To Do With All That “New Cash” + Recent Developments

August 9, 2018

Presenter: Todd Lard

Join the roundtable community now!

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.

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 StoreGoogle Play and the Amazon Appstore.

View previously-featured furry friends.

Read our May 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.

FEATURED PUBLICATIONS

  • State Tax After TCJA: Treatment Of International Income
    The Tax Cuts and Jobs Act, P.L. 115-97,[1] made sweeping changes to the Internal Revenue Code, and will have far-reaching implications for state tax systems that broadly conform to the IRC. In this article for Law360, Eversheds Sutherland attorneys Jeffrey Friedman, Eric Tresh, Todd Lard and Todd Betor focus on the major state income tax implications of the TCJA’s international tax provisions, including: the transition tax imposed by revised IRC § 965; the foreign-source dividends received deduction, or DRD, allowed by new IRC § 245A; the tax on global intangible low-taxed income, or GILTI, in new IRC § 951A and related deduction in IRC § 250; the deduction allowed for foreign-derived intangible income, or FDII, in new IRC § 250; and the base erosion anti-abuse tax, or BEAT, imposed under new IRC § 59A.
  • A Pinch of SALT: Implications of the MTC’s Market-Based Sourcing Model Regulations
    It is more complicated to determine an in-state sale regarding the provision of multistate services or licenses of intangibles. Historically, states looked to a taxpayer’s costs of performing the service or licensing the intangible. Some states have become critical of this cost-of-performance method and replaced it with a market-based method of computing in-state sales. In this edition of A Pinch of SALT, Eversheds Sutherland Partner Jeffrey Friedman discusses the recent amendments to the Multistate Tax Commission’s (MTC) Model General Allocation and Apportionment Regulations; how the model regulations can be further improved; how states are responding to the model regulations; and what is next for the MTC.

FEATURED EVENTS

  • Eversheds Sutherland SALT Shakes Things Up in the Big Easy!
    Eversheds Sutherland was delighted to sponsor and lead the two days of TEI’s Audit and Appeals seminar focused on State and Local Tax Controversy (May 2–3, 2018).
  • State and Local Tax Day
    The Eversheds Sutherland SALT team presented at the Tax Executives Institute (TEI) Denver Chapter State and Local Tax Day on May 15, 2018, in Lakewood, Colorado.
  • 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.

EVENTS – LEARN ABOUT OUR UPCOMING EVENTS

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 May submissions is Friday, May 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 StoreGoogle Play and the Amazon Appstore.

View previously-featured furry friends.

The Eversheds Sutherland SALT team presents at the Tax Executives Institute (TEI) Denver Chapter State and Local Tax Day on May 15, 2018, in Lakewood, Colorado. Details of their presentations are below.

The Future of Sales Tax Collection – Update on Wayfair and Sales Tax Preparedness
Speakers: Michele Borens

Oh So GILTI – Update on State Tax Implications of Federal Tax Reform
Speakers: Robb Chase and Maria Todorova

Not A Class Act – The Recent Aggressiveness of Local Taxing Authorities and Class Action Lawsuits
Speakers: Michele Borens

Legislative Roundup – Update on State Tax Legislative Developments
Speaker: Michele Borens and Alla Raykin

Slicing the Pie – Update on State Tax Apportionment Litigation
Speakers: Maria Todorova and Ted Friedman

Eversheds Sutherland was delighted to sponsor and lead the two days of TEI’s Audit and Appeals seminar focused on State and Local Tax Controversy (May 2 – 3, 2018). Over the past two days, the conference featured unique and practical content including:

Industry Perspective on SALT Tax Controversy

Moderated by Jeff Friedman, this discussion demonstrated the perspectives and strategies of in-house state tax controversy practitioners.

Speakers included:

  • Linda Kim, The Wonderful Company
  • Denise Helmken, General Mills
  • Ken Wright, Smithfield Foods
  • Chris Lee, Koch Companies Service

Perspectives from the Other Side – State Tax Attorney Panel

Moderated by Pilar Mata from Tax Executives Institute, state tax attorneys from Maryland, Ohio and Texas revealed their department organization, decision drivers and advice for taxpayers.

  • Ray Langenberg, Texas Comptroller of Public Accounts
  • Christine Mesirow, Taxation Section, Ohio Attorney General’s Office
  • Brian Oliner, State of Maryland

All Rise – A View from the Bench

Moderated by Richard Pomp from the University of Connecticut School of Law, this discussion offered valuable insight into the inner workings of three state adjudicative bodies, best practices for taxpayers and counsel alike, and the jurists’ thoughts on the state of state tax.

  • Martha Blood Wentworth, Indiana Tax Court
  • Douglas Bramhall, California Office of Tax Appeals
  • Cade Cole, Louisiana Board of Tax Appeals

On Wednesday, May 2, Eversheds Sutherland hosted a reception at House of Blues New Orleans. A good time was had by all!

  

 

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: Attorney Todd Betor
  • 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 David Roby
  • SALT controversy and related business decisions
    ES Speaker: Partner Jonathan Feldman
  • 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.

Read our April 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.

FEATURED PUBLICATIONS

Eversheds Sutherland SALT Scoreboard Publication–First Quarter 2018
Eversheds Sutherland SALT releases the ninth edition of its SALT Scoreboard, and the first of 2018. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses and analyze those results. This edition of the SALT Scoreboard includes insights regarding New Jersey’s attempted taxation of foreign source income, Virginia’s corporate income tax addbacks, and Detroit’s sales factor numerator. View our Eversheds Sutherland SALT Scoreboard results from the first quarter of 2018!

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.
  • Georgetown Law’s 2018 Advanced State and Local Tax Institute
    Eversheds Sutherland 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. Eversheds Sutherland Tax hosts and sponsors a welcome reception at our DC office from 6:00–7:30 p.m. Eastern standard time, on May 30, 2018.
  • 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.

EVENTS – LEARN ABOUT OUR UPCOMING EVENTS

We hope to see you at the two-day State and Local Tax Controversy conference next week! Our unique sessions feature state attorneys general, a panel of judges, a hands-on protest workshop and an overview of litigation management technology.

In addition, we are featuring the perspectives of in-house SALT tax controversy practitioners:

Session: Industry Perspective on SALT Tax Controversy

This session, moderated by Jeff Friedman, will demonstrate the perspectives and strategies of in-house state tax controversy practitioners.

Speakers include:

  • Linda Kim, The Wonderful Company
  • Denise Helmken, General Mills
  • Ken Wright, Smithfield Foods
  • Chris Lee, Koch Companies Services

You are invited to register for the entire four-day seminar, or the two days devoted to state and local tax controversy, or whichever combination meets your individual needs.

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.