SALT FORUM SESSIONS
Tuesday, October 28-Wednesday, October 29, 2025 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 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 Consultant, Corteva Agriscience |
| 9:00 | 10:00 | 60 | Point-Counterpoint – Are We in a Post-Nexus World? This session will include a lively debate over the legal and practical issues related to nexus that may or may not exist after Wayfair. On the menu for discussion are topics such as nexus acquired through intermediaries, nexus determined based on apportionment sales, what constitutes business activity for purposes of Public Law 86-272 and other state & local tax statutes, and the circumstances in which nonresidents may be subject to state per- sonal income tax. (60 Min.) | Kendall Houghton (Moderator) Tax Practice Chair, Alston & Bird LLP Nikki Dobay Shareholder, Greenberg Traurig LLP Michael Fatale General Counsel, Massachusetts Department of Revenue |
| 10:00 | 10:15 | Break | ||
| 10:15 | 11:15 | 60 | A Big, Beautiful Discussion of US Tax Legislation and Executive Orders – and How They May Impact SALT This panel will discuss the impact that the current U.S. tax legislative landscape, tariffs, and myriad other Executive Orders have had on the SALT world. The panelists will share their per- spectives on these recent developments with a focus on the administrative and substantive impacts on state taxation and state-specific responses to federal changes – and how those responses have affected state conformity with each other and federal law. (60 Min.)) | Michael Hilkin Partner, McDermott Will & Emery LLP Brian Oliner General Counsel, Federation of Tax Administrators Scott Roberti Executive Director, Tax, EY LLP Chris Wilson (Moderator) Partner, Holland & Knight LLP |
| 11:15 | 12:15 | 60 | A Seat at the Government Roundtable This roundtable of southeastern state tax representatives will provide a unique opportunity to hear directly from the states on the topics important to them. The panelists will discuss key tax policy concerns, technical tax issues, and technological advancements – including agency use of AI – and then open things up for questions from the audience. (60 Min.) | Cameran Clark Department Secretary, Alabama Department of Revenue Christine Lapps Deputy Commissioner, Tennessee Department of Revenue Greg Matson (Moderator) Executive Director, Multistate Tax Commission Frank O’Connell State Revenue Commissioner, Georgia Department of Revenue |
| 12:15 | 1:15 | 35 | Lunch: Navigating the Unknowable All indicators point to a rollercoaster ride for the SALT world over the next 12-18 months. Economic uncertainty? Socio-political upheaval? Big question marks on federal legislation and spending? Equally big question marks on state revenue drivers? How can you find some control in an environment that is starting to look uncontrollable? Planning. (35 Min.) | Brian Kirkell Principal, RSM US LLP |
| 1:15 | 2:15 | 60 | Managing (Tax) Risk Appetite Mitigating tax risk takes many forms. An alternative that continues to gain market attention involves the use of insurance. Material amounts of tax exposure are now being transferred to insurers to alleviate balance sheet and deal related tax risk. This panel will discuss when to consider the use of insurance, the nuts and bolts of securing coverage, positions commonly insured, case examples, and important considerations for companies to consider before seeking a policy. (60 Min.) | Scott Harty Partner, Alston & Bird LLP Bryce Pressentin Senior Vice President, Euclid Transactional Jenny Wong Head of Tax Insurance – Argo Group US |
| 2:15 | 3:15 | 60 | How to Win an Alternative Apportionment Case: A Game of Chutes & Ladders! Navigating states’ alternative apportionment rules can feel like playing an endless game of Chutes & Ladders – one mo- ment you are climbing toward clarity and the next, you’re sliding back down into uncertainty. This pre- sentation will explore states’ alternative apportionment standards, as well as recent cases, while discuss- ing the hurdles and detours taxpayers often face when trying to win an alternative apportionment case. (60 Min.) | Zack Atkins Partner, Pillsbury Winthrop Shaw Pittman LLP Alysse McLoughlin Partner, Jones Walker LLP Breen Schiller |
| 3:15 | 3:30 | Break | ||
| 3:30 | 4:30 | 60 | Precedent & Deference Using case studies, this panel will explore how agency guidance, judicial deference and statutory interpretation can impact the outcome of a state tax dispute. As part of the discussion, the panel will also consider one state’s treatment of a particular tax matter and explore what impact it should have on other states when they consider the same or a similar matter. (60 Min.) | Karen Boucher Managing Member, FIST Coalition LLC Jonathan Feldman Partner, Eversheds Sutherland Joe Garrett Tax Managing Director, Deloitte Shirley Sicilian Retired, KPMG LLP |
| 4:30 | 5:30 | 60 | Evolving Constitutional Limitations on State Taxation States continue to test the federal Consti- tutional limits of their taxing authority, sometimes with success. As a result, the Due Process Clause, Commerce Clause, Equal Protection Clause, First Amendment, Supremacy Clause, and other U.S. Con- stitutional restrictions on state taxation are front and center in state tax litigation. This session will delve into the evolving application of these constitutional limitations in the modern SALT world. (60 Min.) | Jeffrey Friedman Partner, Eversheds Sutherland Marilyn Wethekam Of Counsel, Council on State Taxation |
| 5:30 | Adjourn | |||
| WEDNESDAY | ||||
| 7:00 | Continental Breakfast | |||
| 7:30 | 8:30 | 60 | Ethical Dilemmas For SALT Professionals in the 21st Century In the 21st Century, public and private SALT professionals face an increasing range of ethical dilemmas, primarily stemming from the growing complexities of the state and local tax laws, the fast-moving pace of technology as applied to those laws, and the constant need to balance client representation with duties to the legal and tax systems. During this interactive session, the panelists will present hypotheticals of ethical dilemmas for the audience to resolve and explore how SALT professionals must apply to their daily practices the ethical standards pro- vided by the ABA, state bar associations, the AICPA, and other organizations. (60 Regulatory Ethics Min.) | Jed Bodger Vice President Tax, Sierra Nevada Corporation Janette Lohman Partner, Thompson Coburn Glenn McCoy Jr. Principal, National Tax, Ryan LLC |
| 8:30 | 8:45 | Break | ||
| 8:45 | 9:45 | 60 | Top 10 Sales and Use 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 and administrative decisions. The panel will also discuss tips, risks, opportunities, and mitigation ideas to consider as administrators, taxpayers, and tax practitioners encounter these changes. (60 Min.) | Carolynn Kranz Managing Member, Kranz & Associates / ISTS Steve Kranz Partner, McDermott Will & Emery LLP Lindsay McAfee Cukier Principal, Indirect Tax, Deloitte Tax LLP Justin Stringfield Tax Managing Director, KPMG LLP |
| 9:45 | 10:00 | Break | ||
| 10:00 | 11:00 | 60 | SALT Developments Impacting Multistate Pass-Through Entities Our experienced panelists will survey re- cent state legislative, judicial, and administrative developments, as well as federal legislation 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 Of Counsel, Bradley LLP Kelvin Lawrence Partner, Dinsmore & Shohl LLP Jenn Stosberg Counsel, Multistate Tax Commission |
| 11:00 | 12:00 | 60 | M&A Feud: The Morning After Edition Your transaction closes, but that is when the real games begin. This session will address important practical and technical considerations that should be considered in advance to ensure a smooth and successful transition post-close, including how to: preserve net operating losses/credits,address state conformity to cancelled debt, manage tax savings agreements, define your unitary group, and enforce key provisions in the sale agreement. (60 Min.) | William M. Backstrom, Jr. (Moderator) Partner, Jones Walker Sheelagh Beaulieu Executive Director, State Income Tax, CVS Health Mike Beck Director, Andersen Jeana Parker Principal, State and Local Tax, KPMG LLP |
| 12:00 | 1:00 | Lunch: Hartman’s Tax Trivia Challenge Weird taxes! Strange facts! New laws! Join us for trivia and test your knowledge of items learned in the sessions, with a sprinkle of questions on general tax issues, pop culture, state geography, and assorted oddities. Bring your phone and quick reflexes to play for fabulous prizes. | Eric Anderson (Emcee) Managing Director, Andersen Tax LLC | |
| 1:00 | 2:00 | 60 | Adding SALT to Today’s International Tax ‘Menu’ As the U.S. and International tax environment continues to change on a daily basis, this panel will explore a range of topics of state tax conformity or nonconformity to various federal and international topics, such as TCJA, international tax agreements, GILTI, and more. In addition, the speakers will discuss the complexities that both taxpayers and state tax authorities face in this changing global environment. (60 Min.) | Becky Kennedy Director – State Direct Tax, Nestle USA, Inc Amy Letourneau Senior Manager, Washington National Tax, RSM US LLP Robert Ozmun Partner, PwC US Tax LLP 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 put his winning streak on the line when he takes on decided underdog Goodman. Could this be the year that Goodman breaks through? (60 Min.) | Jordan Goodman Partner, Kilpatrick Townsend & Stockton LLP Richard Pomp Professor, 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 |