Salt Forum Sessions

 

    Tuesday, October 29th - Wednesday, October 30th, 2019  
Start End Minutes Topic Speaker(s)
7:15     Registration  
7:15     Continental Breakfast  
7:50 8:00   Welcome and Introductory Remarks  
8:00 9:00 60

Top Ten Income Tax Cases  

A perennial favorite at the Hartman SALT Forum. Come hear about the top ten cases that should be on your radar, and gain insights on the issues that will have a significant impact in the upcoming year. 

Bruce Fort, Senior Counsel, Multistate Tax Commission; Washington, D.C.

Lynn Gandhi, Partner, Honigman LLP; Detroit, MI

Hollis Hyans, Senior Counsel, Morrison & Foerster LLP; New York, NY

9:00 10:00 60

Wayfair and the Future of State Income Tax Nexus

The constitutional “substantial nexus” requirement for income taxes has always been murky, and it is not certain whether it is now clearer or murkier after Wayfair. This panel will consider how the Wayfair decision intersects with the Court’s Due Process decisions over the past several years and whether the Wayfair decision, which was concerned only with the dormant Commerce Clause, has any effect on PL 86-272. 

Richard Cram, Director, National Nexus Program, Multistate Tax Commission; Washington, D.C.

Brian Kirkell, Principal, RSM US LLP; Washington, D.C.

Mark McCormick, Partner, EY; Atlanta, GA

Arthur Rosen, Counsel, McDermott Will & Emery LLP; Miami, FL

10:00 10:15  

Break

 

10:15 11:15 60

If You Don't Know, Now You Know

For any business, the scariest tax is the one it doesn’t know about, and with counties, cities, and other local governments looking for new sources of revenue, there are more land mines out there than ever. This panel will discuss some of the more far-reaching but under-reported local taxes that businesses should be aware of and will provide guidance on how to protect against accidentally getting caught by a surprising assessment.

Stephen Jasper, Member, Bass, Berry & Sims; Nashville, TN

Mitchell Newmark, Partner, Morrison & Foerster LLP; New York, NY

Carley Roberts, Partner, Pillsbury Winthrop Shaw Pittman LLP; Sacramento, CA

Breen Schiller, Attorney, Horwood Marcus & Berk Chartered; Chicago, IL 

11:15 12:15 60

Market Sourcing in a Brave New World

Market sourcing for the income tax apportionment sales factor has become the rule instead of the exception it used to be. But that just means there are new questions, rather than the old ones. And now in our post-Wayfair world, market sourcing may mean more for purposes of nexus and filing obligations than it does for the apportionment factor. This panel will discuss the different market sourcing issues and developments, explain what they mean to you and your organization, and make bold predictions about the market sourcing future that we will all have to live in.

Joe Garrett, Deputy Commissioner, Alabama Department of Revenue; Montgomery, AL

Maureen Pechacek, Partner, PwC LLP; Minneapolis, MN

Andres Vallejo, Partner, Reed Smith LLP; San Francisco, CA

12:15   35

Lunch 
What is Wrong With Them?

The session will discuss the state and local tax world through the lens of sound policy. It does not help that those making the tax laws have little interest or knowledge in sound tax policy. So it’s an uphill battle.  

David Brunori, Research Professor, The George Washington University; Vienna, VA

1:15 2:15 60

Interest Expense Limitations

IRC Section 163(j), along with other state income tax provisions, limits the deductibility of interest expense. This session will discuss the issues that have arisen from state conformity with Section 163(j), the interaction of the federal provision with the state addback statutes, and how the states’ filing methods impact interest deductibility. 

Jeffrey Friedman, Partner, Eversheds Sutherland (US) LLP; Washington, D.C.

Todd Senkiewicz, 
Managing Director, Deloitte Tax LLP; Atlanta, GA

Marilyn Wethekam, Partner, Horwood Marcus & Berk Chartered; Chicago, IL

2:15 3:15 60

Combined Reporting Trends and Possible Future Developments

As additional states continue to adopt combined reporting - including most recently New Jersey and Kentucky - we see some clear trends that distinguish these new combination statutes from those that were adopted earlier. This panel will consider the recent trends, what’s driving them, and some of the further changes and developments we may expect to see in the future. 

Raymond Freda, Managing Director, Andersen Tax LLC; New York, NY

Brian Hamer, Counsel, Multistate Tax Commission; Washington, D.C.

Shirley Sicilian, National Director of SALT Controversy, KPMG LLP; Washington, D.C.

Mark Sommer, Member, Frost Brown Todd LLC; Louisville, KY

3:15 3:30  

Break

 

3:30 4:30 60

New-Age Mergers & Acquisitions Post-Wayfair and Federal Reform

The panelists will provide a discussion related to the broadening lens of successor liability and risks brought about by Wayfair and Tax Reform when performing due diligence reviews. They will also share insights on how Wayfair and Tax Reform have impacted post acquisition structuring.

William Backstrom Jr., Partner, Jones Walker LLP; New Orleans, LA 

Erik Burgos, State Tax Director, General Dynamics Corporation; Falls Church, VA

Sarah Murray, Principal, Deloitte Tax LLP; Houston, TX

4:30 5:30 60

Pomp vs. Goodman

The never-ending battle of good versus evil continues with a discussion of the latest and greatest cases and evolving trends in the SALT world.  End your day with some laughs and learning as Professor Richard Pomp and Jordan Goodman continue their battle for supremacy in state tax intelligentsia.  

Jordan Goodman, Partner, Horwood Marcus & Berk Chartered; Chicago, IL

Richard Pomp, Professor, NYU/UCONN; West Hartford, CT

5:30    

Adjourn

 
         
TOTAL DAY 515 CLE: 8.58 Hrs.; CPE: 10.3 Hrs. (10 NASBA)   
         
      WEDNESDAY  
7:00     Continental Breakfast  

7:30

 

 

 

 

 

 

 

 

8:30

8:30

 

 

 

 

 

 

 

 

8:45

 

60

Don’t Get Caught in the Ethics Web – Maneuvering Around Sticky SALT Issues in a Technological World

Technology is supposed to make life easy, but it can be an ethical trap too.  This presentation will help you avoid that trap by recognizing and understanding how the various codes of ethics apply to the technology used by SALT practitioners, their employers, and clients.

 

 

Break

Mark Holcomb, Shareholder, Dean Mead & Dunbar; Tallahassee, FL

Janette Lohman, Partner, Thompson Coburn LLP; St. Louis, MO

Glenn Mccoy, Jr., Director, KPMG LLP; New York, NY

 8:45 9:45  60

Top Ten Sales and Use Tax Developments 

In another annual favorite, this panel of not-so-newlyweds will review the year’s hot developments and trends in sales and use tax, including those that are likely to have significant impacts in future years.  

Loren Chumley, Principal, KPMG LLP; Nashville, TN

Carolynn Kranz, Managing Member, Kranz & Associates/ISTS; Washington, D.C.

Steve Kranz, Partner, McDermott Will & Emery LLP; Washington, D.C.

Scott Peterson, Vice President of US Tax Policy & Government Relations; Avalara; Nashville, TN

9:45 10:00   Break  
10:00 11:00  60

Don’t Let Life Pass You By – Developments in the State Tax Treatment of Pass-Through Entities and Their Owners

Pass-through entities (e.g., partnerships, LLC’s and S corporations) continue to be the fastest growing and most popular form of business organization. Yet, the states’ approaches to taxing them are often not carefully defined and differ widely from state-to-state. This presentation will describe the latest state and local tax developments affecting pass-through entities, address the complex state and local tax considerations brought about by federal tax reform, and offer an update on the state implementation of new partnership audit rules mirroring those of the federal government. 

Caragh DeLuca, Partner PwC LLP; Chicago, IL

Bruce Ely, Partner, Bradley LLP; Birmingham, AL

Steven Wlodychak, Principal, EY; Washington, D.C.

 

 11:00 12:00  60

To Be Or Not To Be – Judicial Deference in State Tax Controversies

Every child knows the frustration of a parent answering a question with “because I said so.” The answer is no less frustrating when a taxing authority uses it to defend an assessment or the denial of a refund claim.  Recently, courts have started to question whether they should give deference to the interpretations or positions taken by taxing authorities. This panel will discuss those trends regarding state court deference to taxing authorities.  

Craig Fields, Partner, Morrison & Foerster LLP; New York, NY

Maria Todorova, Partner, Eversheds Sutherland (US) LLP; Atlanta, GA

Martha Wentworth, Judge, Indiana Tax Court; Indianapolis, IN

12:00 1:00   Lunch & Break  
1:00 2:00 60

As The Dust Settles: A Re-examination of State Implications of Federal International Tax Reform In the Midst of 2018 Compliance Season

One year later, this session will explore the evolution of state tax implications from the TCJA’s international provisions, including GILTI, FDII, and the transition tax. Panelists will discuss impacts ranging across the state tax environment, from compliance and reporting to controversy and tax policy. Topics will include the continuing effect of state non-conformity on the repatriation of cash, the latest state legislative and administrative responses, apportionment of, and expense attribution to, GILTI, and other continuing compliance and planning considerations. 

Susan Courson-Smith, Senior Director-Global Tax, Pfizer Inc.; Memphis, TN

John Harper, Director, KPMG LLP; Nashville, TN

Jessica Morgan, Senior Manager, National Tax Department-State Income Tax, EY; Rocky River, OH

Joel Walters, 
Retired State Revenue Director; Eden Prairie, MN

2:00 3:00 60

To Infinity and Beyond: Impact of Wayfair on Marketplace Platforms

This session will look at tax collection responsibilities imposed on the variety of platforms involved in retail sales in large and small marketplaces operating in the sharing economy and throughout the internet.  The panel will explore the constitutional and statutory implications of imposing collection responsibilities from both the business and government viewpoint, including Due Process, Internet Tax Freedom Act, and state statutory issues. They will also discuss discovery, enforcement, and documentation issues, multiple liability concerns, and the availability of penalty waivers and voluntary disclosures for noncompliance. 

June Summers Haas, Partner, Honigman LLP; Lansing, MI

Susan Haffield, Partner, PwC LLP; Minneapolis, MN

Kimberly Robinson, Secretary, Louisiana Department of Revenue; Baton Rouge, LA

Alexandra Sampson, State Tax Counsel, The Hearst Corporation; Charlotte, NC

 3:00      Adjourn  
TOTAL DAY 360

CLE: 6 Hrs. - CPE: 7.2 Hrs.
(7 NASBA)
(Includes 1 Ethics Hour)

 
         
TOTAL  MON 240

CLE: 4 Hrs. - CPE: 4.8 Hrs
(4.5 NASBA) 

Each session
TOTAL TUES/WED 875 CLE: 14.58 Hrs. - CPE:  17.5 hrs. (17.5 NASBA)
(Includes 1 Ethics Hour)
SALT Forum Sessions
TOTAL ALL 3 DAYS 1115 CLE: 18.58 Hrs. - CPE: 22.3
(22 NASBA)
(Includes 1 Ethics Hour)
TOTAL AVAILABLE HOURS