“By far, the most practical and applicable seminar I've ever attended.”

“Great seminar! It was exactly what I needed to get some background on state tax. I feel much more prepared and am thankful for the materials, as well. They will also be very helpful in the months ahead.”

“I would highly recommend this seminar to anyone who is considering attending. I believe I am walking away with substantially more knowledge and clarity in the state income tax area.”

“This was an excellent course and well designed. The speakers were very knowledgeable in their fields and covered a lot of material.”






Interstate Tax Planning

October 25-27
Hyatt Place Dallas North
Dallas, TX

December 6-8
Hotel Intercontinental
Chicago, IL

December 13-15
Hyatt Place US Capitol
Washington, DC



An intensive three-day immersion into the concepts, problems and planning opportunities involved primarily with state income taxation of multistate business. This course is designed for the beginner to intermediate level practitioner; however, even the most experienced state tax professional will obtain practical ideas and valuable information arising from discussions of the latest administrative, judicial and legislative developments in interstate taxation.

Delivery Method: Group-Live.

No prerequisites or advance preparation required.

NASBA Recommended Fields of Study: Taxes, Regulatory Ethics.

Estimated continuing education credit: 24.5 based on a 50 minute hour, including 1 hour for ethics; 20.58 based on a 60 minute hour, including 1 hour for ethics.


Jurisdiction and Nexus: Constitutional limitations on state powers to tax interstate business. Protected solicitation and de minimis activities under Public Law 86-272. Attributional and economic nexus. Consequences of selling over the Internet, through employees or independent contractors, advertising, delivering, owning or leasing property in a state, other issues. Dealing effectively with nexus questionnaires. The applicable standard for franchise, privilege, other non-income taxes and service companies.

Unitary and Separate Accounting: Unitary, combined, consolidated and separate returns: When does the state or the taxpayer have the right to choose? Limitations on the states’ ability to force unitary combination. Tests for determining when a business is unitary after Container and how they may be turned into planning opportunities for the astute tax practitioner.

Business and Nonbusiness Income: The business/nonbusiness distinction as interpreted by UDITPA, Multistate Tax Compact and other states. The latest on the transactional versus functional tests. State taxation of capital gains, dividends, interest, rents, royalties after ASARCO/Woolworth, Allied-Signal and MeadWestvaco. Factor representation and adjustment opportunities.

The Tax Base and Conformity Issues: State tax treatment of income from federal obligations, taxes paid to other jurisdictions, depreciation, net operating losses, 338(h)(10) transactions, passive holding companies, corporate distributions, foreign source income. Planning and refund opportunities. Areas of state taxation that could be impacted by federal tax reform.

Flow-Through Entities: State taxation of flow-through entities and their owners. Types of entities used. Conformity, nexus, unitary, apportionment and tax base issues. Planning opportunities.

Ethics and Managing the State Tax Function: Structuring the state tax planning, compliance and audit activities to maximize effectiveness while complying with personal ethical standards and those set by the AICPA, ABA, local state CPA societies and bar associations. Consideration of Sarbanes-Oxley, ASC 740 (FIN 48) and other developments that have made ethics a more important part of the state tax practice. Procedures for filing refund claims, amending returns, and responding to notices.

The Property Factor: Determining the relevant property and the timing of its inclusion — tangible, intangible, real and personal. Capitalizing leasehold interests. Using original cost, net book value, basis or fair market value to measure the property factor. Impact of depreciation strategies on, and the role of inventories in, the formula. Situs issues. Treatment of specialized industries.

The Payroll Factor: Examining the scope of the payroll factor — wages, salaries and other personal service compensation. Treatment of management fees, partnership reimbursements, outside contractors, leased or shared employees, specialized industries. Ascertaining the place where services are performed — defining “incidental services” and “base of operations.” Using the cash versus accrual method.

The Sales Factor: Determining the type of receipts — tangibles, intangibles, services or a combination — and the proper sourcing method to apply — market, cost of performance, origination and more. Treatment of returns, allowances, installment and occasional sales, discounts; services, rents, royalties, investment income, other intangibles. Throwback, throwout and dock sales.

Current Developments: Current administrative, court and legislative developments on such critical interstate tax topics as: how to identify discriminatory state tax statutes; limitations on the applicability of NOLs; challenges to the increasing use of economic nexus standards for income tax purposes and for other non-traditional state taxes such as the Ohio CAT; how states are defining the unitary concept and business/nonbusiness distinction; apportionment sourcing issues for services and other industries; procedural traps for the unwary. Planning and refund opportunities.

State and Multistate Tax Audits: The audit process – from information requests and extensions of the statute to the final conference. Ethical considerations. Dealing with the consequences of centralized versus decentralized records. Handling a Multistate Tax Commission audit. Conducting audits in an electronic environment.

Problems Session: Practical application of the concepts presented.




Registration

The registration fee is $1175 for the three-day conference and includes continental breakfast, refreshments, specially-prepared seminar materials, and a cocktail reception the first evening of the program. A $50 discount is available if payment accompanies the registration form and is received by Interstate Tax Corporation at least four weeks before a conference date (September 27-TX, November 8-IL, November 15-DC). An additional discount of $80 may be taken only by those practitioners who attend both Sales & Use and Interstate Tax Planning (all week).



For a List of Speakers Click Here
For Registration Information Click Here
For Travel & Lodging Information Click Here
For a Registration Form Click Here
For a Full Brochure Click Here

For more information, please contact info@interstatetaxcorp.com

Registration for these conferences is not available online.



To return to the Conference Calendar, please click here.


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Copyright © 2015 Interstate Tax Corporation
Last Updated: August 18, 2017