The Institute provides the perfect setting to meet practitioners from around the country. It’s an opportunity to share ideas, exchange views, learn what others are doing, and obtain credit for continuing education. At the Institute, you will:
Learn about the year’s most important state and local tax developments from a national perspective
Obtain up-to-date analyses of state tax developments
Explore the most important professional challenges and ethical dilemmas that are reshaping the profession
Develop a working knowledge of the current trends in areas of state and local taxation, such as state taxation of digital services and products; scrutiny of intercompany transactions; handling an MTC audit; gross receipts taxes; and more
Key topics to be discussed:
Evaluating Formulary Apportionment of State Corporate Income Tax
Can’t Find the Remote? State Tax Issues Associated with A Dispersed Workforce
Super-Marketplace Sales Tax Issues
Overview And Preview of Federal Constitutional Issues
Notable Developments Affecting the Multistate Taxation of PTEs
Os and 1s – State Taxation of Digital Services and Products
New Ethical Challenges Arise as Life with The Covid-19 Pandemic Becomes The ‘New Normal’
Tax Accounting for Salt
Gross Receipts Taxes
Handling An Mtc Audit And Some Of The Hot Issues The Mtc Is Generating
Bad [Inter] Company? Scrutiny Of Intercompany Transaction
What ’S Happening Everywhere Today? Including Local Taxes
Date: December 12 - 13, 2022
John P. Barrie, Esq | Bryan Cave Leighton Paisner
Professor Barrie is a Partner in the law firm of Bryan Cave Leighton Paisner LLP. He is the former Attorney-Advisor to the Honorable Leo H. Irvin of the U.S. Tax Court. Professor Barrie has chaired several committees on tax issues of the ABA and is a member of tax sections of state bars and bar associations in California, Missouri, New York and the District of Columbia. He is a member of the American Bar Association Section on Taxation and is a past vice-chair to the section.
He is a past chair, Committee on Affiliated and Related Corporations; past chair, Committee on IRS Regional Liaison Meetings, past chair, Committee on Government Submissions, past Council Director to the section and a member of the American Bar Association Section on Litigation; past chair, Subcommittee on State and Local Tax Controversies and Litigation, the Missouri Bar (past chair, Taxation Committee); the State Bar of California (member, Tax Section), the District of Columbia Bar (member, Tax Section, past chair), the Bar Association of Metropolitan St. Louis (member, Tax Section), the New York State Bar (member, Tax Section), and the Executive Committee of the National Association of State Bar Tax Sections (past chair); Fellow and Regent (2nd Circuit), American college of Tax Counsel; listed in the The Best Lawyers in America.
Bruce P. Ely, Esq | Bradley Arant Boult Cummings
Bruce Ely’s more than 35 years of experience have allowed him to handle projects as diverse as serving on the recruiting teams that successfully induced both Mercedes-Benz and Hyundai to locate their first U.S. manufacturing plants in Alabama to representing taxpayers before the Internal Revenue Service, the Alabama Department of Revenue and local taxing authorities. His practice focuses on three concentric areas: representing taxpayers in federal, state and local administrative and judicial forums; advising companies on choosing the proper form of entity through which to conduct business in the southeast and potential tax incentives; and advising companies and various trade and professional organizations regarding state and local tax legislative matters. He also devotes a substantial amount of time to teaching and writing on SALT-related topics.
Bruce was founding chair of the firm’s State and Local Tax (SALT) Practice Team, which represents taxpayers before the Alabama, Tennessee and Mississippi Departments of Revenue, as well as local government taxing authorities and the state and federal courts. He has served as counsel to multistate taxpayers in cases before the U.S. Supreme Court, but more often before the Alabama appellate courts, circuit courts, and the Alabama Tax Tribunal. He also recently co-chaired the New York University Institute on State & Local Taxation and was selected by State Tax Notes/Tax Analysts as one of its “Top Ten Tax Lawyers in the U.S.”
As part of his governmental affairs practice, Bruce has co-authored a number of landmark pieces of tax and business entity legislation in Alabama and numerous statute-specific tax bills. He was privileged to serve as counsel to several state tax reform, economic development and constitutional reform commissions over the years and has written extensively on those topics, as well as on other multistate tax issues and incentives matters. He also speaks regularly on the tax aspects of pass-through entities at the national and state levels, and co-authors a series of charts on the state taxation of LLCs and LLPs that have appeared in numerous tax and business entity journals and treatises.
Bruce also serves as co-lead editor of Bloomberg BNA’s Pass-Through Entity Navigator, a comprehensive online resource providing detailed analysis and practical guidance on a state-by-state basis for each type of pass-through entity and pass-through entity owner. The resource tool allows tax professionals to quickly access more than 1,700 topics, such as formation, federal tax classifications, taxes imposed, withholding, or composite returns, and is available to subscribers of Bloomberg BNA’s Tax & Accounting State Tax research.
As a longstanding Fellow of the American College of Tax Counsel, Bruce is the only Alabama member included in the International Who’s Who of Corporate Tax Lawyers.
Jeffrey A. Friedman, Esq | Eversheds Sutherland
Honored as “Tax Lawyer of the Year” in 2011 by State Tax Notes, Jeff Friedman provides sophisticated state and local tax planning, strategic advice and advocacy to numerous Fortune 100 and industry-leading companies. His comprehensive practice includes state and local tax planning, compliance, legislation and policy, and litigation and controversy matters involving income, franchise, sales and use and property taxes. Jeff’s clients span a variety of industries, including e-commerce, energy, technology and telecommunications.
A recognized thought leader on state and local tax issues, Jeff works on high-profile and precedent-setting litigation and controversy matters across the country. These matters impact critical questions on nexus, apportionment, the Multistate Tax Compact and the equal protection, due process and commerce clauses of the United States Constitution. Jeff is also a well-respected advocate on issues of tax policy, including the taxation of digital economy transactions.
Prior to joining Eversheds Sutherland (US), Jeff was a partner in KPMG’s Washington national tax practice; served as an attorney-adviser in the U.S. Department of the Treasury’s Office of Tax Policy, where he assisted with the development of the U.S. government’s position on domestic and international electronic commerce tax issues; and served as vice president and counsel of the Committee (now Council) On State Taxation (COST).
Lynn Gandhi, Esq | Foley Lardner
Lynn A. Gandhi is a partner and business lawyer with Foley & Lardner LLP. Lynn is based in the firm’s Detroit office where she is a member of the Tax, Benefits & Estate Planning Practice.
Practicing for more than three decades, she has acquired a wealth of experience as a sophisticated tax attorney, including 14 years as corporate in-house counsel, providing her extensive knowledge of the challenges facing businesses in their tax reporting obligations, risk management and planning. Lynn advises her clients on sophisticated multistate tax planning opportunities, manages complex audits, and provides transactional support on the multistate tax implications of merger and acquisition transactions, including the defense of post-closing indemnity and escrow claims related to pre-closing liabilities and the use of voluntary disclosure programs to mitigate such claims.
She is also a successful litigation attorney in tax matters at the administrative, trial and appellate levels and has handled matters across the U.S. Lynn is also a registered lobbyist and represents clients in legislative and policy initiatives across multiple industry platforms. Her clients include foreign-based companies with U.S. operations, national Fortune 500 companies, as well as several trade associations. She is sought out for her practical approach to resolve controversy matters, and when settlement is not possible, her strategic approach to litigation to avoid unnecessary “scorch earth” litigation.
Lynn is well-known for her enthusiasm and engagement with tax policy initiatives affecting taxpayers and is frequently sought out as a subject matter expert in her professional community. She has lead legislative and administrative changes large and small to benefit business entities and their owners. Lynn is particularly well-versed in Michigan taxes, including unemployment taxes, gaming excise taxes, captive insurance company taxes, officer liability exposure, offers-in-compromise, and unclaimed property laws.
Lynn has written extensively, and frequently speaks on state tax matters, having published more than 60 articles and spoken or presented at over 100 events. She currently writes a State Tax Notes column entitled “Smitten with the Mitten.” Lynn is also an adjunct professor at Wayne State University Law School, her alma mater.
In addition to being an accomplished state tax attorney, Lynn is a licensed Certified Public Accountant (CPA) in Michigan and Illinois.
Richard W. Genetelli, CPA | Genetelli Consulting Group
Richard was previously with Coopers & Lybrand (now PricewaterhouseCoopers) for 20 years, having served as partner for 10 of those years. Richard was at the forefront of the state and local tax practice at Coopers & Lybrand, having served as the national and regional leader, before leaving to form The Genetelli Consulting Group in 1991. Each of the Firm’s tax professionals has more than two decades of concentrated experience in the state and local tax area.
Specialties: Richard’s firm addresses issues over the spectrum of state and local taxes in all 50 states, including corporate income and franchise, sales and use, personal income, gross receipts, business license, property, realty transfer, payroll, and estate and gift. The firm also assists law firms, accounting firms and professional organizations throughout the country on state and local tax issues.
Matthew P. Hedstrom, Esq | Alston & Bird
Matthew P. Hedstrom is a partner and leads the firm’s State & Local Tax Practice. He focuses his practice on state and local tax planning and controversy and addresses clients’ multistate tax issues, including state income tax apportionment, tax base, business/nonbusiness income determinations, telecommunications and sales/use tax nexus, sourcing and taxability issues and unclaimed property matters. Matthew also advises clients on the state and local tax implications of restructuring, mergers, acquisitions and dispositions, including multistate compliance, voluntary disclosure, planning, audit defense and legal opinions. He also has tax controversy experience at the audit, administrative and appeals level in several jurisdictions.
Matthew has been published on a wide variety of state tax topics in different journals, including State Tax Notes and Journal of Multistate Taxation and Incentives. He regularly speaks on state and local tax matters and has spoken at events hosted by Council On State Taxation (COST), the Tax Executives Institute (TEI), New York University’s Summer Institute in State and Local Taxation and Bloomberg BNA, and the Unclaimed Property Professionals Organization. Matthew is also the editor of the State and Local Tax Edition of the American Bar Association’s Tax Lawyer.
Joe Huddleston, Esq | Ernst & Young LLP
Managing Director at EY LLP.
Hollis L. Hyans, Esq.
Ginny Buckner Kissling | Ryan
PRIVATE SECTOR EXPERIENCE
Global President and Chief Operating Officer, Ryan, Dallas office
Leads Ryan’s Global Operations of more than 3,000 employees spanning the Asia-Pacific, Canada, Europe, and United States, including Service Delivery, Business Development, and Shared Services.
Member, Board of Managers, Ryan, LLC
Principal, Transaction Tax, Ryan, Dallas office
President, U.S. Operations, Ryan, Dallas office
Led 1,300 employees across the United States, as well as 350 employees in Hyderabad, India.
Responsible for all aspects of service delivery within the United States, including 17 practices and 75 sub-practices, Business Development, and Quality Assurance.
Council On State Taxation
Institute for Professionals in Taxation
Interstate Tax Corporation
National Business Institute
New York University, Institute on State and Local Taxation
WFAA–TV, ABC Affiliate – Interview
Ms. Kissling has written articles for the New York University, Institute on State and Local Taxation and Institute for Professionals in Taxation.
Jack R. Kramer, MBA, JD, LLM | PricewaterhouseCoopers
Jack Kramer leads PwC’s National State Income/Franchise Tax practice. In this role, he leads a team of roughly 500 professionals and works frequently on large-scale client engagements. His specialty is in handling complex multistate income/franchise tax matters involving restructuring, audit defense, refund reviews, planning, and compliance. Jack has helped dozens of PwC’s Fortune 500 clients with tax-reduction strategies for their returns, continuing operations, and mergers and acquisitions.
Jack has more than 24 years of experience in the field, and is a frequent speaker on state and local tax issues. He has authored numerous articles on state tax issues for BNA and State Tax Notes. Jack received his B.S. from Fairfield University, his J.D./M.B.A. from Syracuse University, and his LL.M. in taxation from New York University School of Law.
Carolynn S. Kranz, Esq | Industry Sales Tax Solutions
Carolynn is the founder and managing member of two firms: (1) Kranz & Associates, PLLC, a boutique law firm specializing in state and local tax consulting; and (2) Industry Sales Tax Solutions, LLC (“ISTS”), which offers a subscription database containing the sales and use taxability of software related transactions, digital content and cloud services. The ISTS database is also licensed by Avalara and utilized to maintain content as part of their AvaTax platform. Carolynn specializes in state and local tax matters on a multi-state basis, particularly in the area of sales and use taxes. In addition to Carolynn’s sales and use tax expertise, she has significant experience in state and local income / franchise tax, as well as federal tax matters.
Carolynn has over twenty-five years of experience in state and local taxation coupled with over seven years of experience in federal taxation. Prior to founding ISTS, Carolynn spent most of her career working in the state and local tax practice of Big Four public accounting firms. In addition, Carolynn has held a management position in the Tax Department of an international pharmaceutical company with responsibilities involving federal and international tax matters, coupled with a primary focus in state and local taxation.
Carolynn holds a law degree from Widener University School of Law and a Bachelor’s Degree in Management with a major in Accounting and a minor in Spanish from Widener University. Carolynn is a CPA; a member of the District of Columbia and Pennsylvania bars; and also a member of various professional organizations, including the ABA, AICPA, IPT, District of Columbia Bar Association, Pennsylvania Bar Association and the Pennsylvania Institute of Certified Public Accountants. Carolynn is also a member of the advisory committee to Widener University’s Department of Taxation and Accounting, has served as a visiting professor at Widener University, and was an adjunct professor in Widener University’s Master of Taxation Program. She is also a member of the Advisory Board to NYU’s Annual Institute on State & Local Taxation; and is a member and officer to the board for the Streamlined Sales Tax Business Advisory Council
Carolynn was recognized by State Tax Notes in its monthly State Tax Spotlight, which regularly profiles a person or organization influential in the state and local tax world. In addition, Carolynn is a frequent speaker on multi-state sales and use tax matters for clients, businesses, and a number of professional organizations, including the ABA, COST, IPT, New York University, PICPA, and TEI. Carolynn has also authored a book published by LexisNexis – State Tax Guide to Digital Content and Cloud Services, 1st through 6th Editions; a chapter of IPT’s book on Sales and Use Taxation; numerous articles for LexisNexis’ Practitioner Insights; and has been published in State Tax Notes, BNA, and the Pennsylvania CPA Journal.
Lindsay LaCava, Esq | Baker McKenzie
Lindsay M. LaCava is a Partner of the Firm’s Tax Practice Group in New York and is a member of the Firm’s Global Indirect Tax Steering Committee. Lindsay advises individual and business clients on a full range of state and local tax issues. She was ranked by Chambers in 2019 and 2020, was named a “Rising Star” in Tax Law in 2015 by Law360, has been recognized by International Tax Review in its “Women in Tax” Leaders Guide since 2016, and has been recognized by Super Lawyers as a New York-Metro “Rising Star” for Tax since 2013.
Prior to joining Baker McKenzie, Lindsay was a partner in the state and local tax group of an international law firm. In addition, she previously worked at a Big Four accounting firm, where her practice focused exclusively on state and local tax. Lindsay speaks on a variety of state tax topics at events around the country and also frequently writes about state and local tax issues, including serving as the former Managing Editor (State and Local Tax) for the American Bar Association’s “The Tax Lawyer,” co-authoring Bloomberg’s Connecticut Corporate Income Tax Navigator, and co-authoring Checkpoint Catalyst’s New York Corporate Franchise Tax guide. She also teaches State and Local Tax as an adjunct professor at Quinnipiac University School of Law.
Lindsay focuses her practice on state and local tax. She assists businesses and individuals with state and local tax planning and litigation matters. In the controversy area, she represents taxpayers at all levels of state and local tax disputes throughout the country, including the audit, administrative appeal, and state trial, appellate and supreme court stages. In the transactional planning and consulting area, Lindsay advises clients with respect to the state and local tax impact of various transactions and activities, including business activity taxes, sales and use taxes, transfer taxes, and personal income taxes.
Kelvin M. Lawrence, Esq | Dinsmore & Shohl
Kelvin is a business and tax lawyer who saves clients money by minimizing their tax exposure and finding solutions to their Ohio and multi-state tax issues. He advises on taxes implicated in multi-state transactions and has resolved Ohio state income tax, sales tax, commercial activity tax, pass-through entity tax, municipal income tax, and property tax appeals. Kelvin helps his clients manage interactions with taxing authorities and get the most from the involvement of expert witnesses and consultants in tax and unclaimed property audits and controversies.
He has secured significant refunds in Ohio sales tax proceedings, as well as in real property tax exemption and valuation disputes. Kelvin has helped tax-exempt organizations obtain and preserve federal tax-exempt status by advising them on joint ventures, combinations, restructuring, compensation procedures, charitable activities, financial assistance policies, and helping them receive tax-exempt bond financing.
Douglas L. Lindholm, Esq | Council on State Taxation
Douglas L. Lindholm, Esq. is President and Executive Director of the Council On State Taxation (COST). COST, with a membership of over 550 multistate corporations, is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of multi-jurisdictional entities. Prior to taking the helm at COST, Mr. Lindholm served as Counsel, State Tax Policy for the General Electric Company in Washington, DC, and as Senior Manager in the Washington National Tax Office of Price Waterhouse LLP. He has written numerous articles on federal, state, and local tax issues in a wide variety of publications; testifies frequently before state legislatures and Congress on state tax issues; offers commentary on radio and television; and is a frequent speaker at national tax conferences and seminars.
Mr. Lindholm serves on the NYU State and Local Taxation Advisory Board; the Advisory Board of the Paul J. Hartman State and Local Tax Forum; the Advisory Board of the National Multistate Tax Symposium; the Board of Trustees of the New England State & Local Tax Forum, and the Editorial Advisory Board of Tax Management, Inc.
He also serves on the Board of Directors and as President of COST’s research affiliate, the State Tax Research Institute (STRI). He is a former member of the National Tax Association’s Board of Directors and the Advisory Board of the Georgetown University Law Center State and Local Tax Institute. He is a member of the US Supreme Court and District of Columbia Bars.
In 2006, Mr. Lindholm was named to the Tax Business 50 list of most influential tax professionals on the globe and is the recipient of the 2009 New York University Award for Outstanding Achievement in State and Local Taxation. He was also named to the “All-Decade State Tax Team” by State Tax Notes in January 2010 and is the recipient of the COST 2019 Paul Frankel Excellence in State Taxation Award. He is a graduate of American University’s Washington College of Law in Washington, DC, and Lynchburg College (BA in Accounting) in Lynchburg, Virginia.
Stephanie Anne Lipinski Galland, Esq | Williams Mullen
Stephanie Lipinski Galland has extensive legal experience in state and local taxation with an emphasis on representation before state and local taxing authorities in income, franchise, sales, use and unclaimed property controversies. She has represented clients in developing, implementing and defending tax positions in state audits. Her experience in a Fortune 500 company, as a tax partner in a national law firm and in the Virginia Department of Taxation provides her with valuable skills in all areas of taxation.
Stephanie’s experience includes working on a firm government contracts team with government contractors in developing responses to federal and state RFPs, subsequent modifications and appeals of terms and conditions. She has worked on multistate, state and local income, sales and property tax issues with a concentration on matters regarding tax and business planning, mergers and acquisitions (including due diligence issues), administrative appeals and negotiated settlements, tax incentive negotiations and maintenance, audits, unclaimed property issues including audits and voluntary disclosures, tax audits and multistate voluntary disclosures. Stephanie has additional experience in European VAT and Canadian HST. She advises clients on record maintenance as it affects audits, tax record maintenance and SEC issues.
She has also worked with contractors on compliance issues under the Federal Acquisition Regulation (“FAR”) and the Federal Acquisition Streamlining Act of 1994 (“FASA”) to ensure that the underlying contracts meet all necessary requirements. In addition, she has worked with clients on proprietary information disclosure agreements (unilateral and bilateral), memorandums of agreement, teaming agreements and due diligence for teaming agreements.
She possesses broad experience in corporate governance, including interaction with operations and supply chain functions. This experience includes structuring domestic and international transactions, negotiating contract terms with third party vendors, negotiating with governments on the national, state/provincial and local levels for economic development projects and finance and tax accommodations.
Stephanie also drafts and negotiates tax provisions in licensing agreements between brands and affiliated companies for both trademark and trade dress and with unrelated parties for use of various trademarks.
Stephanie’s experience in both the corporate and law firm environment provides her with an understanding of how to work within a team not only to plan but to implement overall goals and objectives. In 2018 and 2020, she was recognized in Washingtonian magazine’s list of the best lawyers in D.C. for tax law.
A frequent author and presenter, Stephanie is sought for her extensive knowledge in the area of taxation. She lectures on the State and Local Tax Program at Georgetown University Law School as an adjunct professor. She earned her B.A. from Christopher Newport University and her J.D., with an Emphasis on Taxation, from the College of William & Mary.
Fred O. Marcus, Esq | HMB Legal Counsel
For over four decades, Fred has provided state and local tax counsel to an impressive list of multistate and multinational corporations. From planning for tax obligations to the successful resolution of tax disputes, Fred has seen just about everything. He has appeared before the United States Supreme Court and the California Supreme Court and has argued before the Illinois and Missouri Supreme Courts. He has also argued before the Illinois, Maryland, New Mexico and New Jersey Appellate Courts and has tried cases before trial courts and administrative tribunals of numerous other states.
Throughout his career, Fred has lectured before the Council on State Taxation, the Tax Executives Institute, the Chicago Tax Club, New York University’s Conference on State and local Taxation, Vanderbilt University School of Law’s Paul J. Hartman State and Local Tax Forum, Georgetown University School of Law’s Institute on State and Local Taxation and the California Tax Policy Conference. Fred is also an adjunct professor of law at Northwestern’s Pritzker School of Law where he teaches state and local taxation in its Graduate Tax Program.
Fred has been instrumental in helping build a nationally recognized state and local tax team to address and support the needs of the Firm’s clients.
Fred will complete his transition to a well-deserved, reduced role in December 2022. While he will remain available for limited strategic consultations and litigation support, other members of HMB’s SALT Group will take the lead.
If you have any questions, please contact State and Local Tax Group Chair, Chris Lutz or any other member of the Firm’s State and Local Tax Group.
Pilar Mata, Esq | Tax Executives Institute
Pilar Mata is Executive Director for Tax Executives Institute, the pre-eminent global association of in-house tax professionals, comprised of nearly 7,000 members from 3,000 of the largest companies in North America, Europe, Latin America, and Asia. Pilar is responsible for leading TEI’s professional staff, guiding and implementing its agenda in consultation with TEI’s International President, Executive Committee, and Board of Directors, and interacting with TEI’s chapters, committees, government relations, and other constituents.
Pilar joined TEI as Tax Counsel in 2015, when she supported TEI’s State and Local Tax, European Indirect Tax, and Canadian Commodity Tax Committees in their advocacy and educational efforts on behalf of the Institute. She was elevated to TEI’s Director of Operations in December 2020, when she assumed responsibility for TEI’s day-to-day operations and led the Institute’s team of professionals.
Before joining TEI, Pilar provided her clients with strategic advice on state and local tax matters and represented them in controversy matters at the audit, administrative, trial, and appellate levels at Sutherland Asbill & Brennan LLP (2009-2015) and Morrison & Foester LLP (2000-2009). Pilar earned her J.D. from the University of California at Berkeley School of Law, her M.S. in Finance from San Diego State University, and her B.B.A. from the University of San Diego. She is a frequent author and speaker, and holds positions on the Advisory Board for NYU’s Institute on State and Local Taxation and New York State’s Tax Appeals Tribunal Advisory Panel. State Tax Notes recognized Pilar in 2017 for her work on the partnership audit rules project.
Gregory S. Matson, Esq | Multistate Tax Commission
Executive Director at the Multistate Tax Commission.
J. William McArthur, Jr., Esq | TE Connectivity
Alysse McLoughlin, Esq | Jones Walker
Alysse provides broad-ranging state and local tax counsel to clients across the country. With years of experience in private practice, as in-house tax counsel at leading financial institutions, and as an attorney in the Chief Counsel Division of the Internal Revenue Service, she understands the goals and priorities of businesses and tax authorities. Alysse draws on this knowledge to help clients make effective tax-planning decisions and resolve tax disputes.
Alysse advises on multistate tax matters, with an emphasis on New York and New Jersey issues. She has represented airlines, media and entertainment companies, banks and financial institutions, and other taxpayers before the New York State Tax Appeals Tribunal and the New York Appellate Division with respect to corporate income tax, insurance tax, bank tax, and sales tax issues. She has represented pharmaceutical companies, utilities, and other clients in New Jersey courts.
Alysse served as head of state tax for Barclays Capital, where she oversaw all state tax matters, including income, sales and use, franchise, excise, and other tax issues. Among other responsibilities, she established the company’s tax-return filing positions and reserves, participated in the development of financial statements and reports, consulted on the structuring of commodity transactions, and responded to audits conducted by state tax authorities. Prior to joining Barclays and after leaving the IRS, Alysse was state tax counsel for Lehman Brothers.
Mitchell Newmark, Esq | Blank Rome
Mitchell defends audits and litigates U.S. state and local tax matters before judicial courts and administrative tribunals around the country. He has successfully argued cutting edge, precedential tax matters before state high courts, intermediate appellate courts, and trial courts on behalf of clients obtaining favorable outcomes across a wide range of industries.
He advises clients on all state and local income, gross-receipts, franchise, sales, use, excise, and miscellaneous taxes as well as myriad fees and unclaimed property obligations. He counsels clients on state and local aspects of sophisticated planning and transactional matters, such as acquisitions; dispositions; restructurings; and asset-based financing transactions, including inventory and off-take financing agreements. He has also successfully counseled individuals and estates regarding residency, domicile, and multistate taxability in audits and appeals.
Mitchell was named a Law360 Tax MVP in 2019. He routinely publishes articles on U.S. state and local taxation, which have appeared in leading industry publications such as Tax Executive, The Professional Journal of the Tax Executives Institute; Deal Lawyers; Law360 Tax; the New Jersey Bar Association Taxation Law Section Newsletter; the DealLawyers.com blog; State Tax Notes; COST State Tax Report; Association of Corporate Counsel; and Tax Management’s Multistate Tax Report.
He also frequently delivers lectures on state and local tax issues and has spoken before numerous organizations, including the New York University’s (“NYU”) Institute on State and Local Taxation; Georgetown University Law Center’s Advanced State and Local Tax Institute; New York University’s School of Professional Studies Tax Conferences in July; Vanderbilt University Law School’s Paul J. Hartman State and Local Tax Forum; The Tax Executives Institute; The Council on State Taxation; The Energy Tax Association; STARTUP; North Eastern States Tax Officials Association; New Jersey CPA Society; New Jersey Bar Association; New Jersey Society of Enrolled Agents; and the Chicago Tax Club.
Prior to joining Blank Rome, Mitchell was a partner at a leading Am Law 100 firm and spent six years as a deputy attorney general at the New Jersey Attorney General’s Office, where he represented the Division of Taxation, among other agencies and bodies, in court. He also counseled the Division of Taxation and other agencies on regulatory matters. From 1996–1997, he served as a law clerk for the Honorable Irwin I. Kimmelman, New Jersey Superior Court, Appellate Division.
Richard D. Pomp, Esq | University of Connecticut
Richard D. Pomp is the Alva P. Loiselle Professor of Law. He is a summa cum laude graduate of the University of Michigan and a magna cum laude graduate of Harvard Law School. He has taught at Harvard, New York University, Columbia, University of Texas, and Boston College. In addition, he has been a Distinguished Professor in Residence, Chulalongkorn Law School, Bangkok, Thailand, and a Visiting Scholar at the University of Tokyo Law School and at Harvard Law School.
Professor Pomp has been qualified as an expert witness in more than 30 states and the federal district courts and has appeared in more than 120 cases. He serves as counsel and a litigation consultant to law firms, corporations, accounting firms, and state tax administrations. He has participated in various capacities in U.S. Supreme Court litigation.
Professor Pomp has also served as a consultant to cities, states, the Multistate Tax Commission, the Navajo Nation, the U.S. Congress, the U.S. Treasury, the Department of Justice, the IRS, the United Nations, the IMF, the World Bank, and numerous foreign countries, including the People’s Republic of China, the Republic of China, Indonesia, the Gambia, Zambia, Mexico, the Philippines, Pakistan, India, and Vietnam. He is the former Director of the New York Tax Study Commission. Under his tenure, New York restructured its personal and corporate income taxes, and created an independent tax court.
Professor Pomp’s casebook, State and Local Taxation, now in its 9th edition, has been used in more than 100 schools, state tax administrations, and major accounting firms for their internal training. Portions of the casebook have been translated into Chinese, Dutch, German, Japanese, Spanish, and Vietnamese. He is also the author of more than 110 articles, numerous chapters in books, and various books and monographs. His writings have appeared in The New York Times, The Wall Street Journal, and the Financial Times.
In addition to the local and regional media, Professor Pomp has been interviewed by CNN, NPR, Bloomberg Radio, Sirius Radio, KCBS, WINA, The New York Times, The Wall Street Journal, The Washington Post, the Christian Science Monitor, the Los Angeles Times, the Minneapolis Star Tribune, the Sacramento Bee, The Baltimore Sun and The International Herald Tribune.
In 2007, he received the NYU Institute on State and Local Taxation Award for Outstanding Achievement in State and Local Taxation. In 2011, he was awarded the Bureau of National Affairs (BNA) Lifetime Achievement Award. He was the 2012 winner of the University of Connecticut’s Faculty Excellence in Teaching – Graduate Level. Tax Analysts selected him as its 2013 State Tax Lawyer and Academic of the Year. In 2014, he received the Council on State Taxation’s Excellence in State Taxation Award. The Connecticut Law Tribune selected him for a 2015 Professional Excellence Award. In 2017, he won the Perry Zirkel ’76 Distinguished Teaching Award. In 2022, he was appointed a Board of Trustees Distinguished Professor, the highest honor the University can bestow on a faculty member.
Michael R. Raley, Esq | VF Corporation
Mike Raley is a Senior Director of Corporate Tax at VF Corporation, a Fortune 250 company. Founded in 1899, VF Corporation is one of the world’s largest apparel, footwear and accessories companies connecting people to the lifestyles, activities and experiences they cherish most through a family of iconic outdoor, active and workwear brands including Vans®, The North Face®, Timberland® and Dickies®. Our purpose is to power movements of sustainable and active lifestyles for the betterment of people and our planet.
At VF, Mike is responsible for state and local direct and indirect taxes (planning, policy, controversy, incentives, etc.), IRS controversy, and mergers & acquisitions. Prior to VF, Mike worked in KPMG’s State and Local Tax Practice for nearly 17 years focusing on planning, controversy, mergers, acquisitions, and divestitures. Mike started his career at Arthur Andersen, and while in law school he clerked for the South Carolina Department of Revenue’s Litigation Division.
Mike serves on the Council of State Taxation’s (COST) Board of Directors, the Advisory Board for the NYU Institute on State and Local Taxation, and the North Carolina Chamber of Commerce Tax Committee. Mike frequently serves as facilitator at COST’s audit sessions held at their annual conferences, and while at KPMG presented at numerous COST regional conferences.
And lastly, Mike graduated from the Darla Moore School of Business at the University of South Carolina with a B.S. in Accounting, cum laude, and from the University of South Carolina School of Law.
Anthony Robinson, Esq | Ernst & Young LLP
Partner at EY’s Oceania Cyber Security Practice specialising in advising clients.
Lead major Cyber Security transformation programes delivering change for some of the world’s largest organisations in Europe and Australia.
This includes completing a cyber security readiness assessment for clients in the insurance industry, working to shape cyber defence services and associated operating models for multinational telecos, delivering major IAM programmes, shaping and delivering SAP GRC programmes in the oil and gas sector, as well as working for a major financial services organisation helping set-up a cyber defence capability.
David is the Co-Chair of Stevens & Lee’s State and Local Tax Group. He focuses on representing clients in complex state tax controversies during audits, before administrative boards and in courts across the country. David also provides sophisticated multistate tax advice to his clients regarding their business operations, assists with navigating the state tax implications of corporate mergers and acquisitions and consults with clients and their lobbyists on pending state tax legislation and regulations.
With nearly 30 years of experience in state tax, David brings to his clients an extensive knowledge of state tax law, strong relationships with state revenue departments, a track record of successfully litigating state tax cases and a deep understanding of procedural and strategic aspects of handling complex state tax audits and appeals. David has extensive experience in all areas of state taxation including state corporate income, sales and use, personal income, utility, insurance company and realty transfer taxes. He also advises clients on tax incentives, unclaimed property and unemployment compensation issues. David has handled audits, administrative appeals and litigation across the country and in states including New Jersey, New York, Pennsylvania, Massachusetts, Connecticut, Maryland, Delaware, New Hampshire and Rhode Island.
David is a frequent national speaker on multistate tax topics for many organizations, including the Council on State Taxation, the New York University Institute on State and Local Taxation, the Institute of Professionals in Taxation, the Tax Executives Institute, the Practicing Law Institute, the Georgetown Advanced State and Local Tax Institute, the Wall Street Tax Association – State and Local Tax Committee, the Pennsylvania Bar Institute, the New Jersey State Bar Association, the New Jersey Society of Certified Public Accountants and the New York State Society of Certified Public Accountants.
David is a member of the American Bar Association’s State and Local Tax Committee, a member of the advisory board for the New York University Institute on State and Local Taxation, a founding committee member for the Institute for Professionals in Taxation’s Income Tax Schools and has served as a member of New Jersey’s Corporation Business Tax Study Committee. He also is a member of the New Jersey Chamber of Commerce’s and New Jersey Business and Industry Association’s Joint State Tax Committee and frequently contributes to those organization’s legislative and regulatory efforts.
Additionally, David has published state tax articles in State Tax Notes, the American Bar Association’s The State and Local Tax Lawyer and Commerce Clearing House’s State Tax Review and he is frequently contacted by news organizations to comment on emerging state tax issues.
Shirley K. Sicilian, Esq | KPMG LLP
Shirley Klenda Sicilian is National Director of State and Local Tax Controversy in KPMG LLP’s Washington National Tax office. In this role, Ms. Sicilian is responsible for supporting KPMG’s network of controversy specialists in every state and coordinating delivery of KPMG controversy services nationwide.
Marc A. Simonetti, Esq | Pillsbury Winthrop Shaw Pittman
From controversy to consulting, Marc Simonetti advises clients on matters across the United States in all areas of state and local taxation, including income, franchise, excise, sales and use tax.
Marc zealously represents clients in controversy matters from audit through litigation—defending clients’ positions and working to achieve practical solutions to controversy matters. He represents clients in matters ranging from administrative appeal to appellate litigation and advises clients on audit matters before state tax authorities, including administrative appeals. Further, Marc represents clients in all aspects of litigation—from discovery, depositions, motion practice, trial and appeal. Recognizing the inherent risks in litigation, Marc is skilled in attaining the best resolution for the client.
Mark F. Sommer, Esq | Frost Brown Todd
With his local and national recognitions, Mark is a highly sought-after attorney resident in the firm’s Louisville office where he leads the firm’s Tax, Benefits and Estates Practice Group and practices in the areas of state, local and federal tax, tax controversy and litigation, and economic development/incentives.
In small matters as well as in “bet the company” situations, Mark has assisted his clients in avoiding hundreds and hundreds of millions of dollars in improperly asserted tax obligations and securing hundreds of millions in refunds and credits. His successes have lead to a national reputation as a practitioner and as a thought leader in State Taxation. He is a go-to advisor on State and Local Taxes in this part of the Country. With nearly 35 years of private practice experience, Mark has on a local, regional and national level successfully counseled and advocated in well more than a thousand federal, state and local tax matters, cases and planning/transactions involving multiple types of businesses, entities, trusts and individual taxpayers. He has also represented more than 110 members of the past and present Fortune 500.
Applying creativity, experience and work ethic, Mark serves his clients daily on all elements of state, local and federal taxation as well as civil/criminal tax controversy/litigation, business law, gaming law, economic development and incentives, tax-related governmental relations and bankruptcy taxation, with significant experience in the manufacturing space, and the automotive and maritime industries.
As a thought leader on taxation, over the years Mark has moderated, presented or spoken at more than 270 seminars and conferences sponsored by various organizations, including the Council on State Taxation, American, Kentucky and Louisville Bar Associations, Institute for Professionals in Taxation, Hartman SALT Forum, Southeastern Association of Tax Administrators, NYU Advanced SALT Conference, TEI and many more organizations.
Philip M. Tatarowicz, CPA, JD, LLM | Georgetown Law
Professor Tatarowicz is a Professor in the Graduate Tax Program at Georgetown and Faculty Advisor of the State and Local Tax (SALT) Certificate Program. He is also Of Counsel at the law firm of Blank Rome LLP in Washington, D.C. Professor Tatarowicz has taught at the Law Center as an adjunct professor since 1984, and became a full-time professor in the Graduate Tax Program in 2011. Prior to joining the Law Center full-time, he served as the national leader of the State & Local Tax Practice at Ernst & Young LLP.
He teaches and writes on issues that address multijurisdictional taxation, federal limitations on the powers of subnational governments to tax, the federal income taxation of partners and partnerships, as well as U.S. Tax Systems, Limitations and Policies, which he taught as a Visiting Professor of Law at the Hebrew University of Jerusalem. Also, Professor Tatarowicz has served as faculty advisor to the Tax Lawyer and The State and Local Tax Lawer. And, since 1982 has chaired the Law Center’s Advanced State and Local Tax Institute.
Jason R. Wyman, CPA | Deloitte Tax
Jason is a Deloitte Tax Partner based in Chicago and work with organizations as a Multistate Key Account Partner. He specializes in all aspects of comprehensive state and local tax planning and reporting. In addition, He serves as Deloitte’s Multistate Inbound Leader and assist numerous non-US headquartered multinationals; from those just entering the United States market to those that have been doing business in the states for many years.
He is a graduate of the University of Nebraska-Lincoln and have received a Bachelors of Science in Business Administration – Accounting Emphasis and a Masters of Professional Accountancy.
He is a licensed CPA in Nebraska and Illinois and am a member of the American Institute of Certified Public Accountants, and the Illinois and Nebraska State Societies of Certified Public Accountants.
Jamie C. Yesnowitz, Esq | Grant Thornton
Jamie Yesnowitz, principal serving as the State and Local Tax (SALT) leader within Grant Thornton’s Washington National Tax Office, is a national technical resource for Grant Thornton’s SALT practice. He has 22 years of broad-based SALT consulting experience at the national and practice office levels in large public accounting firms.
Yesnowitz has extensive knowledge of state corporate income and sales tax legislation and policy; state tax conformity to federal tax provisions; state tax reaction to significant court decisions; and state corporate income tax apportionment rules. He has written numerous articles and is frequently quoted in national publications, including the Wall Street Journal, Bloomberg BNA Daily Tax Report, Tax Analysts State Tax Today, AICPA Tax Adviser, and the Journal of Multistate Taxation and Incentives. Prior to entering the field of public accounting, Yesnowitz practiced law as a corporate and securities attorney in New York.
DAY 1: MONDAY, DECEMBER 12, 2022
Evaluating Formulary Apportionment of State Corporate Income Tax – Lynn A. Gandhi, Esq., Marc A. Simonetti, Esq., and Moderator – David J. Shipley, Esq. | 8:30am – 9:20am
There have been significant legislative and administrative changes to corporate income tax apportionment formulas, including apportionment of sales other than sales of tangible personal property. The panel explores recent decisions and pending cases regarding the apportionment of capital transactions, intangible income, and services, as well as the ability of states and taxpayers to invoke alternative apportionment formulas.
Can’t Find the Remote? State Tax Issues Associated with A Dispersed Workforce – Jamie C. Yesnowitz, Esq., Edward A. Zelinsky, Esq., and Moderator – Eugene J. Gibilaro, Esq. | 9:20am – 10:10am
The increase in employers hiring employees in multiple states and the increase in telework due to the pandemic has created new state and local tax issues and compliance challenges for employers and employees alike. This panel discusses the many state and local tax issues that arise from having a dispersed workforce, including nexus considerations, withholding tax considerations, and state-specific rules seeking to tax employees of an in-state business who are teleworking from other states.
Break | 10:10am – 10:25am
Super-Marketplace Sales Tax Issues – Richard Cram, Esq., Matthew P. Hedstrom, Esq., and Moderator – Michele Borens, Esq. | 10:25am – 11:15am
Marketplace Mayhem: The ink is barely dry on states’ marketplace laws, but we are already experiencing implementation issues. The panelists provide a review of emerging issues, including determining the scope of marketplace laws, mitigating double-taxation, and complying with exemption certificates and other administrative burdens.
State Tax Implications of The Ira and Other Federal Conformity Issues – Bruce J. Fort, Esq., Todd Roberts, Esq., CPA, and Moderator – Karl A. Frieden, Esq. | 11:15am – 12:00pm
The federal Inflation Reduction Act of 2022 includes an expansive new corporate book-income alternative minimum tax (CAMT). This session provides a brief overview of how the CAMT works and analyzes any potential short-term and long-term state tax implications. The panelists also discuss the hangover impact of the federal Tax Cuts and Jobs Act and lingering state conformity issues relating to foreign source income, interest expense deductions and amortization of research expenditures.
Lunch Break | 12:00pm – 1:00pm
Overview And Preview of Federal Constitutional Issues – Jeffrey A. Friedman, Esq., Richard D. Pomp, Esq. | 1:00pm – 2:00pm
The most significant constitutional cases in state taxation over the past year, both in the US Supreme Court and in state courts, are surveyed. The commentators provide a spirited preview of important cases to watch in the coming year.
Notable Developments Affecting the Multistate Taxation of PTEs – Chris Barber, Esq., Dale Y. Kim, CPA, Kelvin M. Lawrence, Esq., and Moderator – Bruce P. Ely, Esq. | 2:00pm – 3:00pm
The rapid rise of state pass-through entity (PTE) taxes affects nearly every enterprise. This panel discusses PTE taxes, including financial accounting implications; the MTC’s ambitious Partnership Tax Project and an update on its Model Partnership Audit/RAR Statute; recent developments in the state taxation of capital gains when a nonresident owner sells its ownership interest to a third party; and other recent PTE SALT developments.
Break | 3:00pm – 3:15pm
Os and 1s – State Taxation of Digital Services and Products – Gilbert Brewer, Esq., Michael Kelley, Esq., Lindsay LaCava, Esq., and Moderator – Carolynn S. Kranz, Esq. | 3:15pm – 4:15pm
Cloud services and digital goods and services remain a hot topic among state legislatures and departments of revenue. This session includes an update on the work taking place on digital goods and services at the Multistate Tax Commission as well as Streamlined Sales Tax Project. The speakers also cover anticipated and unique trends in taxing the digital space.
New Ethical Challenges Arise as Life with The Covid-19 Pandemic Becomes The ‘New Normal’ – Matthew J. Landwehr, Esq., Kathleen M. Quinn, Esq., and Moderator Glenn C. McCoy, Jr., CMI, Esq. | 4:15pm – 5:15pm
The coronavirus (COVID-19) pandemic caused unexpected changes and disruptions to society during 2020 and 2021, including to the legal and accounting professions. Now that 2022 is drawing to a close, attorneys and accountants must consider existing and newly enacted ethical obligations. Many state bar and CPA associations have published new guidance to help their members with their ethical duties as COVID-19 continues to plague us (unfortunate pun intended?). Certain actions by the New York State Bar Association, DC Bar Association, North Carolina Bar Association, and the Michigan Bar Association are highlighted in this session.
DAY 2: TUESDAY, DECEMBER 13, 2022
Tax Accounting for Salt – Anna Cronic, CPA, Mark McCormick, MBA, and Moderator – Todd G. Betor, Esq. | 8:30am – 9:25am
The accounting for state and local tax consequences can be intimidating to say the least. This panel demystifies it. Topics covered include a description of the application of ASC 740 and ASC 450, valuation allowances, and deferred tax assets. In addition to covering the basics, the discussion dives into specific hypotheticals that are intended to provide practical application of some not-so-practical accounting rules.
Gross Receipts Taxes – Michelle DeLappe, Esq., Richard D. Pomp, Esq., and Moderator Douglas L. Lindholm, Esq. | 9:25am – 10:15am
Gross receipts taxes and their variants are experiencing a resurgence over the past few years, with the adoption of Oregon’s CAT, Nevada’s Commerce Tax, Maryland’s Digital Advertising Tax, and countless local and municipal gross receipts-based taxes. This session explores the downside of gross receipts taxes, why such taxes should not be a part of any state’s revenue program, and the expensive and complex litigation that inevitably follows their adoption.
Refreshment Break | 10:15am – 10:30am
Handling An Mtc Audit And Some Of The Hot Issues The Mtc Is Generating – Holly Coon, Joe Garrett, Esq., Alysse McLoughlin, Esq., and Moderator – Shirley K. Sicilian, Esq. | 10:30am – 11:20am
Panelists discuss the Multistate Tax Commission’s audit program, along with other ongoing or recently completed MTC projects that are likely to impact taxpayers in the future. The audit discussion covers how taxpayers are selected, how the process differs from a typical state audit, best (worst) practices for getting through it, and why some taxpayers have actually requested an MTC audit.
Bad [Inter] Company? Scrutiny Of Intercompany Transaction – Michael J. Bryan, CPA, Sherri H. York, CPA, and Moderator – Mitchell A. Newmark, Esq. | 11:20am – 12:15pm
Intercompany transactions are often the subject of disagreement between taxpayers and states but related party arrangements are a basic part of economic business life and are not going away. This panel provides an overview of transfer pricing concepts, the necessity of intercompany agreements, discusses reasons for transfer pricing, pain points in transfer pricing, and state efforts to challenge and resolve intercompany transaction related disputes.
Lunch Recess | 12:15pm – 1:15pm
What ’S Happening Everywhere Today? Including Local Taxes – Moderators – Ginny Buckner Kissling, Douglas L. Lindholm, Esq., David A. Hughes, Esq., William McArthur, Jr., Esq. | 1:15pm – 4:30pm
Get ready for a jam-packed show! It’s hard to cover the ever-changing state and local tax landscape, but an all-star team of “special reporters” provides a rundown of what you need to know about the most important SALT developments affecting taxpayers today. Dateline focuses on issues with local taxes. Then, stick around for “Meet the Press” and a panel discussion on important developments in the New York / New Jersey / Pennsylvania region.
Special Reporters: Richard M. Botwright, Esq., Jaye A. Calhoun, Esq., Richard W. Genetelli, CPA, Stephanie Gilfeather, Esq., Richard L. Jones, Esq., Burnet R. Maybank III, Esq., Sarah McGahan, Esq., Michael Puzyk, Esq., Timothy G. Schally, Esq., Mark F. Sommer, Esq.