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.

• SALT Pet of the Month: Gracie
  Meet Gracie, the 15-week-old Australian Shepherd/Golden Retriever mix belonging to Eversheds Sutherland SALT Of Counsel Doug Mo and his wife Marcia.
• South Dakota v. Wayfair – Insights and Analysis
  On April 17, the US Supreme Court heard arguments in South Dakota v. Wayfair, a case involving the states’ authority to tax online purchases. This is the first sales tax jurisdiction case heard by the US Supreme Court in 25 years and may have a significant impact on online sales across the country.
• Georgia Legislature Enacts Significant Income, Sales, and Property Tax Legislation
  The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation.
• Maryland Enacts Legislation Adopting Single Sales Factor Apportionment
  On April 24, Maryland Governor Larry Hogan signed Senate Bill 1090 and House Bill 1794, which adds Maryland to the growing list of states that are moving towards a single sales factor formula to apportion corporate net income.
• New Mexico Finds No Obstacle to Inclusion of Foreign Dividends and Subpart F Income in Consolidated Return Base
  The New Mexico Administrative Hearings Office affirmed the Taxation and Revenue Department’s assessment based on General Electric’s exclusion of foreign dividend and Subpart F income from its base income in its New Mexico consolidated return.
• New York State Budget Adopts Substantial Changes in Response to Federal TCJA
  The New York Legislature passed its 2018-2019 Fiscal Year budget on March 30, 2018, which is expected to be signed into law by Governor Cuomo.
• Oregon Legislature Passes IRC Conformity Legislation, But Decouples from Certain Federal Tax Reform Provisions
  On April 10, 2018, and April 13, 2018, Oregon Governor Kate Brown signed into law S.B. 1529 and S.B. 1528 (the Bills), respectively, which provide a series of changes to Oregon’s income tax laws in response to recent federal tax changes as part of the federal Tax Cuts and Jobs Act.
• Pennsylvania Court Finds Wholesaler of Electricity Subject to Gross Receipts Tax
  The Commonwealth Court of Pennsylvania affirmed a decision by the Board of Finance and Revenue that found American Electric Power Service Corporation (“Taxpayer”) was subject to Pennsylvania’s gross receipts tax as a wholesale seller of electricity.
• What are the State Tax Implications of International Tax Reform?
  What are the State Tax Implications of International Tax Reform? Jeff Friedman and others outline the key points at the COST 2018 Spring Audit Session/Income Tax Conference in snowy Boston, Massachusetts.

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.

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 a practical focus on the ins and outs of protests:

Session: Challenging Assessments and Filing Protests

Decisions made at the protest level shape the chances of success and the cost of litigation. This session will highlight the tactical considerations and most effective strategies in challenging assessments and filing protests.

Speakers include:

• Michele Borens, Partner, Eversheds Sutherland
• Eric Coffill, Senior Counsel, Eversheds Sutherland

Session: Protest Workshop

Hone your protest skills in a real-time practical working session. Learn the best ways to challenge a hypothetical protest, and review strategies and tactics successfully employed by other practitioners.

Facilitated by:

• Carley Roberts, Partner, Eversheds Sutherland
• Scott Wright, Partner, Eversheds Sutherland

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.

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. 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.

View event details.

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.

 

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.

View previously-featured furry friends.

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!

EVENTS – LEARN ABOUT OUR UPCOMING EVENTS