SALT FORUM SESSIONS
| Tuesday, October 27 & Wednesday, October 28, 2026 All Times Listed are Central Time Zone | ||||
| Start | End | Minutes | Topic | Speaker(s) |
| 7:15 | Registration and Continental Breakfast | |||
| 7:45 | Welcome and Introductory Remarks | |||
| 8:00 | 9:00 | 60 | Top Ten Income Tax Cases to Watch A perennial favorite of the Hartman Forum, this panel will once again review the top ten income tax cases from the past year, provide insights into the issues that the panelists expect to dominate in the coming year, and offer some entertaining questions to test your knowledge 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 | All About the Acronyms: State Taxation of Foreign-Source
Income Foreign-source income can pro- duce very different results for state tax purposes than it does federally. This session will provide a practical framework for analyzing the constitutional, conformity, income inclusion, deduction, apportionment, and reporting issues that are created when states seek to tax foreign income. (60 Min.) | Zack Atkins Partner, Pillsbury Winthrop Shaw Pittman LLP Alysse McLoughlin Partner, Jones Walker LLP Marilyn Wethekam Of Counsel, Council on State Taxation |
| 10:00 | 10:15 |
Break | ||
| 10:15 | 11:15 | 60 | Big Gains, Bigger Questions: Rethinking State Taxation of High-Value
Transactions This panel will trace the evolving state approaches to taxing large gains, from business versus non-business income distinctions and allocation frameworks to more aggressive regimes involving alternative apportionment, mark-to-market concepts, and commercial domicile. Panelists will highlight emerging risks, planning con- siderations, and audit trends affecting complex multistate structures. (60 Min.) | Karen Dean SVP, Global Tax, Lumen Technologies John Fletcher Partner, Jones Walker LLP Nicki Howard Shareholder, Greenberg Traurig, LLP Richard Pomp Professor of Law, University of Connecticut & NYU |
| 11:15 | 12:15 | 60 | Fault Lines in TPP Sourcing: When Delivery Isn’t
Determinative Single-sales-factor apportionment has exposed fault lines in traditional place-of-delivery sourcing for tangible personal property. Concen- trating receipts in a single location can produce distorted results that may not reflect economic reality, raising renewed questions about alternative apportionment. This panel will examine recent case law and legislative developments and provide practical guidance for identifying risk and defending sourcing po- sitions in this unsettled area. (60 Min.) | Joe Garrett Tax Managing Director, Deloitte Tax LLP Stephen Jasper Member, Bass, Berry & Sims PLC Breen Schiller Shareholder, Greenberg Traurig, LLP |
| 12:15 | 12:50 | Tax Analysts Award of Distinction Luncheon for State and Local
Taxation The Tax Analysts Award of Distinction recognizes exceptional contributions that have strengthened state and local taxation through innovation, leadership, public service, and meaningful impact. Join colleagues from across the SALT community as we celebrate this year’s honoree and their contributions to advancing more effective, transparent, and accountable tax systems. | ||
| 12:50 | 1:25 | 35 | The SALT Wall of Shame Enjoy your lunch while listening to a vibrant discussion of cases, legislation, and policy decisions that never should have happened. This will be a lighthearted presentation to remind attendees that common sense can often save judicial and legislative resources. (35 Min.) | Billy Hamilton Columnist, Tax Notes State Nicole Johnson Partner, Blank Rome LLP |
| 1:30 | 2:30 | 60 | Digital Ad Taxes: Panacea or a Bill of Goods? More states are moving toward imposing taxes on digital advertising. This session will provide a description of the different approaches states have taken to tax advertising. The speakers will also address the policy and legal implications of these taxes. Get ready for a spicy debate! (60 Min.) | Jeff Friedman Partner, Eversheds Sutherland (US) LLP Brian Oliner General Counsel, Federation of Tax Administrators Richard Pomp Professor of Law, University of Connecticut & NYU |
| 2:30 | 3:30 | 60 | Everything Everywhere All at Once: AI Is Not Just
ChatGPT! Artificial Intelligence is all the rage, but what is AI? Meaningful differences among AI applications may drive tax consequences and related obligations. In this session, we will explore the scope of AI and its various applications, from self-driving vehicles to intelligent chatbots to medical research analysis. The panelists will discuss the broader scope of AI, and how evolving technology impacts the imposition of direct and indirect taxes. (60 Min.) | Eric Anderson Managing Director, Andersen Mo Bell-Jacobs Senior Manager, RSM US LLP Daniel Dubin Partner, Alston & Bird LLP |
| 3:30 | 3:45 | Break | ||
| 3:45 | 4:45 | 60 | Administration Insights: A State Tax Leaders
Roundtable This panel brings together state tax administrators to offer front-line perspectives to discuss how their agencies are deploying AI, as well as the growing impact of taxpayer use of AI on compliance and controversy. The panel will also explore issues related to data centers, developments in estate and wealth taxation, and the practical challenges states face in maintaining revenue and closing budget gaps during periods of fiscal pressure. (60 Min.) | Greg Matson (Moderator) Counsel, Eversheds Sutherland (US) LLP Sharonne Bonardi Executive Director, Federation of Tax Administrators Amanda Hiller Acting Commissioner, New York State Department of Taxation and Finance McKinley Wooten, Jr. Secretary, North Carolina Department of Revenue Zachary Wyatt Legislative & Business Relations Director, Missouri Department of Revenue |
| 4:45 | 5:45 | 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 devel- opments and administrative decisions. The panel will also discuss tips, risks, opportunities, and mitigation ideas to consider as administrators, taxpayers, and tax practitioners encounter these developments. (60 Min.) | Carolynn Kranz Managing Member, Kranz & Associates, PLLC Stephen Kranz Partner, McDermott Will & Schulte LLP Justin Stringfield Partner, KPMG LLP Chris Wilson Partner, Holland & Knight LLP |
| 5:45 | Adjourn | |||
| WEDNESDAY | ||||
| 7:00 |
Continental Breakfast | |||
| 7:30 | 8:30 | 60 | Rethinking Ethics: The Impact of AI on State & Local Tax
Professionals As technology, regulatory scrutiny, and client expectations evolve, fundamental ethical principles remain constant. This session will use hypotheticals and audience surveys to examine how standards of integrity, objectivity, and profession- al responsibility apply in the context of AI-driven compliance tools, automation, and emerging risk areas. (60 Regulatory Ethics Min.) | Jedediah Bodger Vice President Tax, Sierra Nevada Corporation Matthew Landwehr Partner, Thompson Coburn LLP Glenn McCoy Jr. Principal, National Tax, Ryan LLC |
| 8:30 | 9:30 | 60 | OBBB Aftershocks: The State Conformity Battles
Continue Fifteen months after enactment of the One Big Beautiful Bill, the state tax landscape continues to evolve. While many states have updated their conformity statutes, others have selectively decoupled from key federal provisions or adopted unique conformity approaches. This session will examine where the states stand today, highlight the policy de- bates shaping conformity decisions, and identify the areas where uncertainty remains. The panel will also explore how the states’ conformity decisions impact state tax planning, compliance, ASC 740, and future legislative activity. (60 Min.) | Barbara Coulter State and Local Tax Partner, PwC US Tax LLP Nikki Dobay Shareholder, Greenberg Traurig, LLPS Jessica Morgan Partner, EY LLP Jared Walczak Senior Fellow, Tax Foundation |
| 9:30 | 10:00 | Government Networking Break Representatives from invited State Departments of Revenue, as well as the FTA and MTC, will be stationed at tables in the break area, ready to make your acquaintance and quickly connect on your issues! | ||
| 10:00 | 11:00 | 60 | The Changing Landscape: State Taxation of Pass-Through
Entities This panel will review all things PTE, including the MTC Partnership Tax Project, state PTE tax developments after the increased SALT cap, election foot-faults, adoption of the MTC Model Partnership Audit/RAR Act, developments in taxing and sourcing gains on PTE ownership interests, and other significant state PTE cases and rulings from the past year. (60 Min.) | Chris Barber Director of Operations, Multistate Tax Commission Bruce Ely Of Counsel, Bradley LLP Kelvin Lawrence Partner, Vorys, Sater, Seymour and Pease LLP |
| 11:00 | 12:00 | 60 | When the Formula Fails: Mismatched Metrics, Distorted Results, and
Constitutional Limits on State Taxation As states and local jurisdictions continue to modernize apportionment rules, tax- payers increasingly face situations where the metrics used to source income bear little relationship to actual economic activity. The result can be double taxation, nowhere income, or significant distortions that raise constitutional concerns. This session will explore the growing tension between state sourcing regimes and constitutional apportionment principles, highlighting emerging controversies, litigation trends, and practical strategies for addressing inequitable outcomes. (60 Min.) | Aruna Chittiappa Partner, Pillsbury Winthrop Shaw Pittman LLP Amber Rutherford Tax Managing Director, Deloitte Tax LLP Andres Vallejo Partner, Vallejo Antolin Agarwal & Kanter LLP |
| 12:00 | 1:00 | Lunch: Hartman’s Tax Trivia Challenge | Eric Anderson (Emcee) Managing Director, Andersen | |
| 1:00 | 2:00 | 60 | Intergovernmental Tax Disputes: When Taxing Authorities Fight Each Other As fiscal pressures and tax complexity increase, disputes for tax dollars among federal, state, and local taxing authorities are becoming more frequent and consequential. This panel will explore recent intergovernmental conflicts over sourcing, municipal taxing authority, preemption, and the limits on state taxation or regulation of multistate entities. (60 Min.) | Andrew Appleby Associate Professor of Law, University of Tennessee Winston College of Law Michael Fatale General Counsel, Massachusetts Department of Revenue Eugene J. Gibilaro Partner, Blank Rome LLP Jennifer Karpchuk Partner, Holland & Knight LLP |
| 2:00 | 3:00 | 60 | Credits & Incentives: What’s Really on the Menu? Credits and incentives are rarely one-size-fits-all. This session will take attendees behind the scene to explore how companies and states are structuring creative credits and incentives deals in today’s competitive, and increasingly scrutinized, environment. Panelists will discuss “off-menu” opportunities, why data center incentives are drawing fire, and what recent case studies reveal about negotiation strategy, compliance, clawbacks, and public perception. (60 Min.) | William M. Backstrom, Jr. (Moderator) Partner, Jones Walker LLP Nicole Gagliastre Credits & Incentives Tax Director, PwC US Tax LLP Laura Moran Director, Andersen Raj Varma Managing Director, KPMG LLP |
| 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 Credit 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 |