44th Institute on State and Local Taxation 2025 (presented by NYU School of Professional Studies) (Day 2)

This session examines how states will react to federal IRC changes under the One Big Beautiful Bill Act. Panelists discuss income tax conformity challenges, the shift from GILTI to NECTI, and what to expect as state legislatures balance revenue concerns with tax policy.

The panel addresses how Maryland, Washington, and other states have transformed their sales tax base through digital services taxation. Presenters examine Streamlined Sales Tax Project guidance development and the goal of achieving uniformity across jurisdictions.

The Paul H. Frankel Memorial Address provides a spirited review of the most significant constitutional cases in state taxation from the past year. Commentators also preview important constitutional cases to watch in the coming year.

This ceremony honors Diann L. Smith as the recipient of the Paul H. Frankel Outstanding Achievement in State and Local Taxation Award. The presentation recognizes exceptional contributions to the field of state and local taxation.

Following the constitutional review, this panel examines the most significant state tax decisions that turned on important non-constitutional issues. Panelists analyze key rulings affecting taxpayers across multiple jurisdictions and practice areas.

As partnerships, LLCs, and complex structures grow in popularity, tax challenges compound for these taxpayers. This panel updates attendees on state approaches to large transaction gains, income tax issues from pass-through ownership, and MTC developments.

This panel discusses tricky ethical issues arising from the filing process through litigation. Topics include disclosures on returns, information requests at audit, discovery processes, and maintaining professional standards throughout tax controversies.

Representatives from states and the business community focus on priorities for their stakeholders and areas where common ground may be attainable. The session provides updates on current projects from both organizations and highlights areas of agreement and disagreement.

Panelists address state treatment of 80/20 companies, worldwide combined reporting, and the transition from GILTI to NECTI. The session also covers sales tax implications of tariffs, the PepsiCo and Agilent cases, and treaty considerations for foreign businesses.

This session examines AI’s growing use in state tax analysis and the taxation of AI solutions. Panelists discuss use cases including data mining, research efficiency, compliance applications, AI limitations like hallucinations, and emerging state guidance on taxing AI services.

Presenters compare sourcing methods for income and sales tax, covering cost of performance versus market-based approaches. The session addresses tangible property sourcing disputes, service sourcing hierarchies, gains from business interest sales, and constitutional limits on sales tax sourcing.

High-ranking officials from New York, New Jersey, Connecticut, and Pennsylvania address critical challenges in revenue collection, resource constraints, and taxpayer fairness. Discussion covers IRS changes impact, workforce challenges, AI in administration, and balancing revenue goals with fair treatment.

Distinguished tax influencers lead an interactive lightning-round tour covering developments across major jurisdictions including New York, New Jersey, Pennsylvania, DMV, Illinois, Wisconsin, Louisiana, Texas, Colorado, Washington, and California. Topics include local tax litigation, digital product taxation, regulatory challenges, and emerging state legislation.