SALT FORUM SESSIONS
Tuesday, October 29-Wednesday, October 30, 2024 All Times Listed are Central Time Zone | ||||
| Start | End | Minutes | Topic | Speaker(s) |
| 7:15 | Registration and Continental Breakfast | |||
| 7:40 | Welcome and Introductory Remarks Presentation of the Paul J. Hartman Award to Joe Huddleston | |||
| 8:00 | 9:00 | 60 | Top Ten Income Tax Cases to Watch: Nothing Trivial Here A perennial favorite of the Hartman Forum, this panel will once again cover the top ten income tax cases that all SALT professionals should be watching, will offer insights into the issues that are likely to dominate in the coming year, and will test your knowledge with some trivia questions about the leading cases. (60 Min.) | Bruce Fort Senior Counsel, Multistate Tax Commission Lynn Gandhi Partner, Foley & Lardner LLP Hollis Hyans Tax Consultant, Corteva Agriscience |
| 9:00 | 10:00 | 60 | Point-Counterpoint / Mandatory Worldwide Combination After 40 years, there is once again a movement to adopt mandatory worldwide combined reporting. This session will begin with an exam- ination of the historical background that led to the repeal of the filing method and the rationale for and problems with the current movement to adopt mandatory worldwide combined reporting before end- ing with a debate on the policy considerations and administrative ramifications of adoption. (60 Min.) | Kendall Houghton (Moderator) Partner, Alston & Bird LLP Michael Mazerov Former Senior Fellow, Center on Budget & Policy Priorities Marilyn Wethekam Of Counsel, Council On State Taxation |
| 10:00 | 10:15 | Break | ||
| 10:15 | 11:15 | 60 | Economic Nexus and More It’s been over six years since the Wayfair decision, and the implications of this landmark ruling are still unfolding. This panel will cover how states and localities have implemented and enforced economic nexus post-Wayfair for both indirect and income taxes and will high- light key differences and trends among the jurisdictions. The panel will also discuss how PL 86-272 applies in a post-Wayfair world and will cover recent challenges to the states’ adoption of guidance interpreting PL 86-272 as applied to business activities over the internet. (60 Min.) | Michael Bowen Partner, Akerman LLP Brian Hamer Counsel, Multistate Tax Commission Shirley Sicilian Managing Director, State & Local Tax Controversy, KPMG LLP Chris Wilson (Moderator) Partner, Holland & Knight LLP |
| 11:15 | 12:15 | 60 | Navigating State Apportionment Join us for an in-depth exploration of the latest trends and developments in state apportionment. From coast to coast, we’ll examine the most recent updates in the sourcing of gains, alternative apportionment, and factor representation. Stay ahead of the curve and gain valuable insights into this ever-evolving topic. (60 min.) | Brad Buchanan Chief Hearing Officer, Tennessee Department of Revenue Mark McCormick Director, Newell Brands Amber Rutherford Managing Director, Deloitte Tax LLP Dan Sieburg Managing Director, Crowe LLP |
| 12:15 | 1:15 | 35 | Lunch – What’s the Next Big Thing for SALT? Over the past decade, the SALT world has been de- fined by a string of game-changers: market-based sourcing, single sales factor apportionment, the rise of digital goods and services, Wayfair, COVID and the post-pandemic boom have been big, impactful topics. But the MTC’s PL 86-272 guidance, digital ad taxes, wealth taxes, and the PTET have not [yet] panned out as SALT-shaking. Has the sizzle turned to fizzle? What’s the next big thing for SALT? (35 Min.) | Brian Kirkell Principal, RSM US LLP |
| 1:15 | 2:15 | 60 | Bon Voyage: “Short Takes” on Multinational Taxation Take a journey as we explore the impact of multinational entities doing business in the US. In this session presenters take turns focusing on multinational topics such as inbound taxation of multinational entities, GILTI/Sec. 174, and Pillar 1/2 issues. (60 Min.) | Doris Cordevant Senior Manager, State & Local Indirect Tax, Emerson Maria Eberle Partner, Baker McKenzie LLP Jessica Morgan Senior Manager, EY US LLP J. Snowden Rives III Senior Manager, Deloitte Tax LLP |
| 2:15 | 3:15 | 60 | Getting SALTy with ASC 740 | 450 If you’re an in-house professional, this is an incredibly important topic every quarter. For practitioners, this is an opportunity cloaked in a technical accounting wrapper, to understand this issue and help your clients. (60 Min.) | Kathryn Friel Assistant General Tax Counsel, Entergy Services, LLC Amy Letourneau Senior Manager, Washington National Tax, RSM US LLP Peter Turner Tax Partner, PwC |
| 3:15 | 3:30 | Break | ||
| 3:30 | 4:30 | 60 | Let’s Get Together, See What’s in the Bag and Acquire Some M&A Knowledge This will not be your typical SALT M&A presentation. In this session, the panel will take its queues from you and your colleagues by grabbing topics from a grab bag of issues provided by the audience. Join an interactive Q&A Session that focuses on current SALT issues and trends in mergers, acquisitions, and business restructurings. The team will dig into their own bag of extensive experience to guide the discussion of SALT issues, due diligence strategies, document preparation, adding value to the transaction team, and any other topic you want to discuss. (60 Min.) | William Backstrom, Jr. Partner, Jones Walker LLP Eugene Gibilaro Partner, Blank Rome LLP Alexis Morrison-Howe Tax Principal, Deloitte Tax LLP |
| 4:30 | 5:30 | 60 | Top Ten Sales Tax Developments This traditional Hartman session will cover the top ten developments in indirect taxes, including significant cases (both decided and pending), and important legislative developments, rulings, and audit developments. The panel will also discuss tips, risks, opportunities, and mitigation ideas to consider as administrators, taxpayers, and tax practitioners encounter these changes. (60 Min.) | Natalie Haynes Partner, EY US LLP Steve Kranz Partner, McDermott Will & Emery Fred Nicely Senior Tax Counsel, Council On State Taxation Justin Stringfield Tax Managing Director, KPMG LLP |
| 5:30 | Adjourn | |||
| WEDNESDAY | ||||
| 7:00 | Continental Breakfast | |||
| 7:30 | 8:30 | 60 | Professional Ethics in an Age of Artificial Intelligence As artificial intelligence becomes integral to tax practices, ethical considerations are paramount. Tax professionals must ensure that AI systems are trans- parent, unbiased, and secure. Key ethical concerns include protecting taxpayer data privacy, ensuring fair and equitable treatment of all clients, and maintaining accountability for AI-driven decisions. This panel will discuss and apply the ABA model Rules, the AICPA Statement on Standards for Tax Services, and the role of IRS Circular 230 to situations involving real-life ethical dilemmas caused by the use or misuse of artificial intelligence, modern technology, and other issues. (60 Regulatory Ethics Min.) | Janette Lohman Partner, Thompson Coburn Glenn McCoy Principal, Client Services, Ryan LLC Mark Yopp Partner, Baker McKenzie LLP |
| 8:30 | 8:45 | Break | ||
| 8:45 | 9:45 | 60 | Recent SALT Developments Impacting Multistate Pass-Through Entities Our experienced panelists will survey recent state legislative, judicial and administrative developments, as well as corollary federal developments and work by the MTC, affecting the taxation of multistate pass-through entities and their owners. The panel will also identify some near-term trends in this complex and ever-evolving area of the law. (60 Min.) | Bruce Ely Partner, Bradley Kelvin Lawrence Partner, Dinsmore & Shohl LLP Brooke Nelson SALT Senior Manager, RSM US LLP |
| 9:45 | 10:00 | Break | ||
| 10:00 | 11:00 | 60 | Agency Guidance and Judicial Deference Following keynote comments on the Loper Bright decision, the panel will consider recent federal and state developments limiting deference and their impacts on state tax administration. Specific areas of discussion will include deference in the context of state tax tribunals, whether less deference mean less agency guidance, and the difference between deference and other rules of statutory interpretation. (60 Min.) | Joe Garrett Tax Managing Director, Deloitte Tax LLP Brian Oliner General Counsel, Federation of Tax Administrators Mark Sommer Partner, Frost Brown Todd LLP |
| 11:00 | 12:00 | 60 | Check Your Receipt: An Update on Sales Factor Apportionment Issues – For better or for worse, the major- ity of states rely on a sales/receipts factor to apportion income for corporate income tax purposes. This panel will discuss recent trends, including the challenges and opportunities, that are present in the world of market sourcing. (60 Min.) | Jeremy Gove Attorney, Eversheds Sutherland (US) LLP Nicole Johnson Partner, Blank Rome LLP Breen Schiller Principal, EY US LLP |
| 12:00 | 1:00 | Lunch: The Ultimate SALT Trivia Challenge! Did you learn a few things at the conference? Prove it! Get ready for a fast-paced romp through state tax trivia – and we may throw in some other random things just for fun. This game will test your knowledge and your reflexes – the first one to get the answer gets the most points. Grab your lunch, take a seat, and play along. You may even win fabulous prizes. | Eric Anderson (Emcee) Managing Director, Andersen Tax LLC | |
| 1:00 | 2:00 | 60 | Intercompany Transactions on the Hot Seat Auditors are increasingly proposing adjustments to prices of intercompany transactions. This panel will discuss how to document intercompany transactions in the first instance and how to work with auditors to ensure that proposed adjustments are consistent with the facts or applicable law. The panel will also discuss other tools that states use to address what they perceive to be abuse, including alternative apportionment, economic substance, addback statutes and more. (60 Min.) | Clark Calhoun Partner, Alston & Bird LLP Jaye Calhoun Partner, Kean Miller LLP Ryan Finley (Moderator) Contributing Editor, Tax Notes Matt Tidwell Assistant Director, Income Tax Audit & Appeals, Alabama Department of Revenue |
| 2:00 | 3:00 | 60 | Pomp v. Goodman A wide-ranging debate on the most important SALT topics of the day. The focus of the discussion will be the most current trends in state and local reporting and litigation. Professor Pomp will attempt to defend his title in this heavy weight battle for SALT supremacy. However, because this is an election year, the audience will be part of the process and will be asked to actively participate by answering questions throughout the presentation. (60 Min.) | Jordan Goodman Partner, Kilpatrick Townsend & Stockton LLP Richard Pomp Professor, New York University/University of Connecticut |
| 3:00 | Adjourn | |||
| 875 | ESTIMATED TOTAL CONTINUING EDUCATION CREDIT HOURS AVAILABLE TUESDAY & WEDNESDAY:875 MINUTES CLE: 14.58 hours (Includes 1 Ethics Hour*); CPE: 17.5 hours (includes 1 Regulatory Ethics Hour*) (17.5 NASBA) | |||
| 1115 | ESTIMATED TOTAL CONTINUING EDUCATION HOURS AVAILABLE MONDAY, TUESDAY, WEDNESDAY:1115 MINUTES CLE: 18.58 hours (Includes 1 Ethics Hour*); CPE: 22.3 hours (includes 1 Regulatory Ethics Hour*) (22 NASBA)*Ethics Hours are subject to approval by the controlling State Boards and are included in the total hours provided. | TOTAL AVAILABLE HOURS |