Lynn A. Gandhi, Esq. | Foley & Lardner LLP

Practicing for more than three decades, Lynn A. Gandhi has acquired a wealth of experience as a sophisticated tax attorney, including 14 years as corporate inhouse counsel, providing her extensive knowledge of the challenges facing businesses in their tax reporting obligations, risk management, and planning. Lynn is a partner in the firm’s Detroit office member of the Tax, Employee Benefits & Executive Compensation, and Estate Planning Practices.

Lynn advises her clients on sophisticated multistate tax planning opportunities, manages complex audits, provides transactional support on the multistate tax implications of merger and acquisition transactions, constructs submissions for tax insurance policies, and assists with unclaimed property audits and voluntary disclosures.

Jeffrey A. Friedman, Esq., Partner | Eversheds Sutherland

Jeff 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.

Eric M. Anderson, Esq. | Andersen Tax

Eric Anderson provides state and local tax services as part of the US National Tax practice. He has expertise in strategic tax planning, controversy representation, and tax risk management for clients across the firm. Eric also focuses on income tax planning and compliance, sales and use tax transaction planning, mergers & acquisitions, local tax matters, and administrative tax controversies. Eric also has extensive experience with unitary tax planning, business and non-business issues, and entity structuring to manage multistate tax liabilities.

Eric serves as an Andersen firm-wide resource for credit and incentive consulting, including negotiated incentives related to company expansions and training activities, as well as statutory tax credits. He has helped clients obtain refunds for a variety of statutory credits aggregating millions of dollars.

Elizabeth S. Cha, Esq., Partner | Eversheds Sutherland

Liz counsels clients on state and local taxation matters.  These matters include sales and use taxes, utility taxes and other taxes imposed on regulated entities. Liz represents clients in tax controversy and counsels clients on state tax planning, structuring and integration. Liz also counsels clients on unclaimed property matters, such as voluntary disclosure and audit management.

Dominic Zambrano, Esq., Senior Director, Tax | Comcast Corporation

Dominic Zambrano is Senior Director of Tax at Comcast Corporation, where he leads strategic tax planning and compliance initiatives across a broad range of corporate transactions and operational structures. With deep expertise in federal income taxation, mergers and acquisitions, and partnership structures, Dominic provides legal and tax guidance that supports the company’s complex business operations and long-term growth objectives. He brings a practical, solutions-oriented approach to navigating evolving tax regulations and has extensive experience collaborating with legal, finance, and executive teams. Dominic is a licensed attorney and a respected voice in corporate tax strategy and policy development.

Michael J. Semes, Esq. | Baker & Hostetler LLP

Mike utilizes over 30 years of government executive, financial and academic experience to drive state and local tax value to his clients in their most significant controversies and transactions.

Mike has served as Pennsylvania Governor Tom Ridge’s Chief Tax Counsel, has been a partner in two ‘Big 4’ firms and is currently a professor of practice at Villanova University Law School Graduate Tax Program. This diverse background enables collaboration with his clients to examine various issues through legal, regulatory, policy, procedural, financial, reputational and academic lenses, leading to practical, goal-oriented solutions. Mike has handled a broad range of tax issues and won significant victories in many state forums. From a sector perspective, he has a wealth of experience working with companies on both the regulated and non-regulated sides of the energy industry. Mike has also been actively involved in following, writing and speaking about the recent trends in adopting and proposing digital advertising taxes.

David Yanchik, Esq. | KPMG

David is a senior manager in the KPMG Pennsylvania Business Unit. David graduated with a degree in Accounting from The Ohio State University and went on to receive his Juris Doctorate from the University of Pittsburgh School of Law. Prior to joining KPMG, David spent a summer interning with the firm and also has experience working for a mid-size law firm and a small sporting goods manufacturer.

David’s experience includes advising on many aspects of multi-state tax matters, focusing mainly on income and franchise tax issues involved in complex corporate transactions (mergers, acquisitions, spin-offs, restructurings, bankruptcies).

With his experience with international and federal tax, David has recently been involved in helping clients understand the state tax impact of tax reform with analysis on mandatory repatriation, GILTI, FDII, and 163(j). Additionally, David has worked with Fortune 50 clients on state tax planning, analysis of state tax attributes following an ownership change, and various state tax controversy matters. David has assisted clients on numerous mergers, acquisitions, and restructurings by helping them to navigate the complex interplay between international, U.S. federal, and state income taxation.

Michele Borens, Esq. | Eversheds Sutherland (US) LLP

Michele Borens advises her clients, many of whom are impacted by taxation in the digital economy, in strategic state and local tax planning. She also defends them in litigation regarding state income and sales tax assessments.

With comprehensive knowledge of individual state tax policies, Michele provides strategic advice on multistate strategies and planning, state-specific tax reductions, transactional planning and reverse income tax reviews. She helps corporate clients reorganize and restructure their projects and advises on travel and business operation expansion into particular states. Michele also represents and defends clients, many of whom operate in the e-commerce and telecommunications industries, in controversy and tax matters, including state tax nexus issues. Michele represents clients nationwide, and has worked extensively with companies that have litigation in Maryland regarding intangible holding companies.

Mark W. Yopp, Esq., Sr. Managing Associate General Counsel | Verizon

Mark W. Yopp serves as Senior Managing Associate General Counsel at Verizon, where he provides strategic legal counsel on federal tax matters, corporate transactions, and regulatory compliance. With extensive experience in both private practice and in-house roles, Mark advises on complex issues involving partnership taxation, M&A structuring, and tax controversy. He plays a key role in shaping Verizon’s tax strategy and navigating the intersection of legal risk, operational impact, and regulatory change. Mark is a seasoned legal executive known for his practical insight and ability to align legal frameworks with business goals in a dynamic corporate environment.

Chelsea E. Marmor, Esq., Counsel | Eversheds Sutherland

Chelsea advises clients across a wide range of industries, including highly regulated sectors such as communications, technology, and public utilities sectors.

To ensure business objectives are achieved in the most tax efficient manner, she provides comprehensive tax support to her clients, including state and local tax (SALT) policy and planning matters. She counsels on all tax types, including sales and use, income, gross receipts, and other local taxes. Chelsea also advises clients in controversy and litigation matters in administrative, civil, and appellate courts across the country.

Nikki E. Dobay, Esq. | Greenberg Traurig, LLP

Nikki Dobay is nationally known for her deep experience and understanding of state tax policy and the legislative process. She also advises her clients on sophisticated multistate tax issues as well as the consequences and planning opportunities related to corporate M&A transactions and oversees state and local tax controversy matters, ranging from audits to appellate litigation, and involving sales and use taxes, income and franchise taxes, property taxes, and constitutional issues.

Nikki regularly engages with statewide business and taxpayer associations and departments of revenue, as well as national tax administrator organizations, including the Federation of Tax Administrators (FTA), the Multistate Tax Commission (MTC), and the National Conference of State Legislatures (NCSL), on key SALT issues impacting multijurisdictional taxpayers.

Jeremy P. Gove, Esq. | Eversheds Sutherland (US) LLP

Jeremy Gove works with clients through various stages of multistate tax planning and structuring, state and local tax (SALT) controversy and litigation and policy matters. Jeremy’s practice involves resolving controversies throughout the litigation process, including trial and appeals. His experience includes counseling clients on a variety of multistate taxation issues, including corporate income, franchise, gross receipts, and sales and use taxes. He hosts the SALT team’s SALT Shaker Podcast, which explores SALT trends and updates.

Prior to joining Eversheds Sutherland, Jeremy worked for a global law firm where he represented clients in income, franchise, gross receipts, and sales & use tax controversy matters throughout the country at the administrative and judicial level.

Timothy A. Gustafson, Esq., Partner | Eversheds Sutherland

Tim focuses particularly on California and other Western states. Tim is extensively experienced on issues and matters before the California Franchise Tax Board, the California Department of Tax and Fee Administration, the California Office of Tax Appeals, the Oregon Tax Court, the Utah State Tax Commission, and other courts and administrative bodies. Tim routinely advises retailers and manufacturers, telecommunications companies, technology service providers, and financial institutions on income and franchise taxes, sales and use taxes, and key-related issues including apportionment, nexus, business and nonbusiness income, penalties, deductions and credits.

Madison Ball, Esq., Associate | Eversheds Sutherland

Prior to joining Eversheds Sutherland, Madison worked for an Am Law 100 law firm where she focused on state and local tax matters, including controversy. Madison also worked for a Big Four accounting firm where she performed M&A due diligence services and advised companies on all state and local tax types.

Todd G. Betor, Esq. | Eversheds Sutherland (US) LLP

Todd Betor focuses his practice on the state and local tax implications of business transactions, including mergers, acquisitions and restructurings.

He advises clients on the impact of federal tax provisions on state taxation. Todd counsels clients in the digital economy, retail and technology industries, with a particular emphasis on marketplace and remote sellers. He guides clients through state tax planning pre- and post-transaction, and provides modeling, guidance and integration recommendations. He also helps clients throughout the reorganization process, from drafting implementation plans to writing tax opinions.

Todd instructs clients on all aspects of state and local tax, including income, franchise, sales and use, telecom and other transaction taxes, as well as tax accounting for state and local taxes. In addition to tax planning, he represents clients in tax controversy and litigation matters, and advises on employment tax withholding, resident status and other state tax issues for clients with mobile, global workforces.

Aruna Chittiappa, Esq. | Pillsbury Winthrop Shaw Pittman LLP

Aruna Chittiappa advises clients on a variety of corporate state and local tax matters, including multistate litigation, planning, audit defense, and controversy issues.

Prior to joining Pillsbury, Aruna worked on international tax treaty matters, the BEPS Action Plan, and inbound taxation issues. Aruna’s experience includes representing Fortune 100 businesses in state and local tax litigation throughout the United States. Aruna’s litigation work ranges from audit defense to multi-state tax litigation and appeals in state courts and tax tribunals. In addition to her litigation work, Aruna advises on state and local tax planning matters involving complex state tax issues.

Ted W. Friedman, Esq. | Eversheds Sutherland (US) LLP

Ted serves as national state and local tax counsel to many of the Fortune 100 and other industry-leading companies.

Ted represents clients in state tax controversy, planning, policy and compliance matters in jurisdictions across the country. He assists with a wide range of issues involving income and franchise taxes, sales and use taxes, gross receipts taxes, property taxes and telecommunication taxes. Ted’s clients span a variety of industries, including banking and financial services, e-commerce, technology and telecommunications.

In addition to Ted’s multistate practice, Ted helps companies from across the country address complex New York State and New York City tax issues, from audit through appellate litigation

Timothy G. Schally, Esq. | Michael Best & Friedrich LLP

Tim provides strategic counsel on tax matters contested by the Internal Revenue Service, the Wisconsin Department of Revenue, and the taxing authorities of other state and local jurisdictions. Contested matters, for Fortune 1000 and other clients, include: Federal income taxation of banks, insurance companies, and manufacturers. Multistate apportionment and allocation of income. Transfer pricing among affiliated entities. Sales and use tax for retailers, manufacturers, and construction contractors.

Kathleen M. Quinn, Esq. | Jones Walker LLP

Katie Quinn is a partner in the Tax Practice Group. She advises businesses across the country on state and local tax planning and tax controversy matters. Katie advises multinational, national, and regional businesses, as well as high-net-worth individuals, on the full spectrum of state and local tax matters. Katie understands how tax strategies fit into her clients’ broader business goals and offers practical, actionable advice to help ensure compliance and resolve disputes with tax authorities. Based in Jones Walker’s New York office, Katie has advised clients on state and local tax issues in all 50 states, with a special focus on the tri-state area: New York, New Jersey, and Connecticut.

Amy Letourneau, Esq., Senior Manager | RSM US

Amy Letourneau is a Senior Manager at RSM US, where she advises clients on a wide range of federal tax planning matters, with a focus on partnership taxation, closely held businesses, and estate and gift tax strategies. As a licensed attorney, Amy brings a legal perspective to complex tax issues, helping high-net-worth individuals and family-owned enterprises implement structures that support long-term growth, compliance, and wealth preservation. She is known for her collaborative approach and ability to translate technical tax rules into actionable planning strategies. Amy regularly contributes to client education and thought leadership on evolving tax law developments.

Robert C. Ozmun, CPA, Partner | PwC

Robert C. Ozmun is a Partner at PwC, where he advises high-net-worth individuals, family offices, and closely held businesses on complex tax planning, wealth transfer strategies, and entity structuring. With deep expertise in partnership taxation, estate and gift tax, and income-shifting strategies, Robert works closely with legal and financial advisors to develop integrated plans that align with clients’ long-term goals. He is known for his ability to navigate technical tax issues while delivering practical, client-focused solutions. Robert is a frequent speaker on advanced tax planning topics and a trusted resource for navigating evolving tax regulations and compliance frameworks.

Jeremy Sharp, Esq, | Deloitte

Jeremy Sharp is a tax attorney with Deloitte, where he advises clients on complex federal and international tax matters, with a particular focus on partnership taxation, business structuring, and estate and wealth transfer planning. Drawing on his legal background and deep technical knowledge, Jeremy helps clients navigate evolving regulatory landscapes and implement tax-efficient strategies tailored to their long-term goals. He collaborates with multidisciplinary teams to deliver practical, compliant solutions to high-net-worth individuals, family enterprises, and closely held businesses. Jeremy is a frequent speaker on tax law developments and strategic planning for private clients.

Leonore Heavey, Esq. | Council On State Taxation

Leonore Heavey is Senior Tax Counsel for the (Council On State Taxation) COST and is the lead advocate for the Northeastern states. Before joining COST, Leonore served as Chief Revenue Counsel for the Louisiana Senate. She began her career in state and local taxation at the Louisiana Department of Revenue where she served in numerous roles during her tenure including Assistant Director of the Policy Services, Tax Administration, and Audit Review divisions. Leonore’s work with the department included serving on their legislative liaison team, drafting tax policy documents, and reviewing corporate income and franchise tax field audits. Her undergraduate degree in Agriculture and masters in Agricultural Economics are from Washington State University. She earned her Master of Laws in Taxation from the University of Denver and her Juris Doctor from the University of Idaho College of Law. Leonore is a member of the Louisiana and Washington state bar associations.

Marilyn A. Wethekam, Esq. | Council On State Taxation

Marilyn A. Wethekam, Esq. is Of Counsel to the Council On State Taxation. COST, with a membership of over 500 multistate corporations, is dedicated to preserving and promoting equitable and nondiscriminatory state taxation of multi-jurisdictional entities. Prior to joining COST Ms. Wethekam was a partner at HMB Legal Counsel in Chicago where she had a national SALT practice representing multistate and multinational corporations in all areas of state tax advising clients on multistate tax issues involving income, franchise, and transaction taxes. Prior to going into private practice, Ms. Wethekam was tax counsel for both Mobil Oil Corporation and Montgomery Ward & Co. where she developed an understanding of the complex issues encountered by multistate and multinational corporations.

Andrew Jay Maschas, Esq. | Comptroller of Maryland

Andrew Jay Maschas serves as legal counsel with the Office of the Comptroller of Maryland, where he focuses on state and local tax policy, regulatory compliance, and enforcement. With a background in administrative and tax law, Andrew advises on a range of matters including corporate income tax, sales and use tax, and multistate tax issues. He plays a key role in interpreting and applying Maryland tax statutes and regulations, offering guidance that shapes both enforcement strategy and taxpayer compliance. Andrew is a seasoned legal professional committed to balancing effective administration with equitable tax policy.

DAY 1: MONDAY, JULY 21

US CONSTITUTIONAL AND OTHER FEDERAL CONSTRAINTS ON STATE TAXATION | 8:25am – 9:30am

Lynn A. Gandhi, Esq., Partner, Foley & Lardner, Detroit, MI

Jeffrey A. Friedman, Esq., Partner, Eversheds Sutherland, Washington, DC

INTRODUCTION TO SALES AND USE TAXATION | 9:30am – 10:30am

• Discussion and Overview of Sales and Use Taxes
• Commonalities and Differences Among State Sales Taxes
• Tangible Personal Property and other Key Definitions
• Credits Against Taxes Paid to Other States

Eric M. Anderson, Esq., Managing Director, Andersen Tax, San Francisco, CA

Elizabeth S. Cha, Esq., Partner, Eversheds Sutherland, New York, NY

Break | 10:30am – 10:45am

SALES TAXATION EXEMPTIONS AND ADMINISTRATION | 10:45am – 12:00pm

• Resale, Manufacturing, Processing Exemptions
• Exemption Certificates Administration
• Streamlined Sales and Use Tax Project and Agreement
• Common Audit Issues

Jeremy P. Gove, Esq., Counsel, Eversheds Sutherland, New York, NY

Dominic Zambrano, Esq., Senior Director, Tax, Comcast Corporation, Philadelphia, PA

Lunch | 12:00pm – 1:00pm

SALES TAXATION OF SERVICES AND OTHER SPECIAL PROBLEMS | 1:00pm – 2:30pm

• Discussion of Taxation of Information, Data Processing, and other  Computer-Related Services
• Apportionment of Service Transactions
• Bundled Transaction and Mixed Sales
• Use Taxation on Mobile Property
• Local Sales and Use Taxes
• Class Action and Qui Tam Litigation

Timothy A. Gustafson, Esq., Partner, Eversheds Sutherland, Sacramento, CA

David Yanchik, Esq., Managing Director, KPMG, Pittsburgh, PA

SALES AND USE TAXATION: SELLING ON A MARKETPLACE | 2:30pm – 3:15pm

• Description of Marketplace Collection Statutes including Notable Similarities and Differences
• Special Issues, including Liability of Third-Party Sellers and Marketplaces, Exemptions and Certificates,
• Michele Borens, Esq., Partner, Eversheds Sutherland US, Washington, DC

Cyavash N. Ahmadi, Esq., Counsel, Eversheds Sutherland US, New York, NY

Break | 3:15pm – 3:30pm

GROSS RECEIPTS TAXES | 3:30pm – 4:30pm

• Description of Various Gross Receipts Taxes, including Washington B&O, Ohio CAT, Texas Margins Tax
• Special Problems, including Apportionment, Pyramiding, Treatment of Intercompany Transactions, and Pass-Through

Mark W. Yopp, Esq., Sr. Managing Associate General Counsel, Verizon, Basking Ridge, NJ

Chelsea E. Marmor, Esq., Counsel, Eversheds Sutherland, New York, NY

STATE TAX RESEARCH TOOLS, TIPS AND TRICKS | 4:30pm – 5:30pm

Elizabeth S. Cha, Esq., Partner, Eversheds Sutherland, New York, NY

Timothy A. Gustafson, Esq., Partner, Eversheds Sutherland, Sacramento, CA

Madison Ball, Esq., Associate, Eversheds Sutherland, New York, NY

DAY 2: TUESDAY, JULY 22

OVERVIEW OF STATE CORPORATE INCOME TAXATION | 8:30am – 9:30am

• Tax Base and Federal Income Tax Conformity
• Common Modifications and Adjustments
• Business Income and Non-Business Income
  • Apportionment versus Allocation

Jeffrey A. Friedman, Esq., Partner, Eversheds Sutherland, Washington, DC

Aruna Chittiappa, Esq., Counsel, Pillsbury Winthrop Shaw Pittman, New York, NY 

APPORTIONMENT OF THE CORPORATE INCOME TAX BASE | 9:30am – 10:30am

• Uniform Division of Income for Tax Purposes Act
  • Overview of the Three-Factor Formula
  • Description of Each Factor and Calculation

Ted W. Friedman, Esq., Partner, Eversheds Sutherland US, New York, NY

Timothy G. Schally, Esq., Partner, Tax Practice Group Chair, Michael Best & Friedrich, Milwaukee, WI

Break | 10:30am – 10:45am

SALES FACTOR: SPECIAL PROBLEMS | 10:45am – 12:00pm

• Moorman and the Constitutionality of the Single Sales Factor
• Sales of Services
  • Costs-of-Performance Issues and Litigation
  • Market-Based Sourcing Issues and Litigation
• Throwback and Throwout

Lynn A. Gandhi, Esq., Partner, Foley & Lardner, Detroit, MI

Kathleen M. Quinn, Esq., Partner, Jones Walker, New York, NY

Lunch | 12:00pm 1:00pm

THE UNITARY BUSINESS PRINCIPLE | 1:00pm – 2:00pm

• Discussion of the Principle and the Roles It Serves in Corporate Income Taxation
• Description of the Various Tests Employed to Apply the Unitary Business Principle
• Special Problems Associated with the Unitary Business Principle

Timothy A. Gustafson, Esq., Partner, Eversheds Sutherland, Sacramento, CA

Jeremy P. Gove, Esq., Counsel, Eversheds Sutherland, New York, NY

STATE CORPORATE INCOME TAX FILING METHODS | 2:00pm – 3:00pm

• Separate, Consolidated and Unitary Combined Returns
  • Water’s Edge versus Worldwide Combined Reporting
• Treatment of Intercompany Transactions
• Application of State Anti-Abuse Rules
  • Addback Statutes
  • Inclusion of Tax Haven Affiliates

Amy Letourneau, Esq., Senior Manager, RSM US, Houston, TX

Robert C. Ozmun, CPA, Partner, PwC, Boston, MA

Break | 3:00pm – 3:15pm

FINANCIAL STATEMENT ISSUES ASSOCIATED WITH STATE TAXATION | 3:15pm – 4:00pm

• Application of ASC 740 (Income Taxes) and ASC 450 (Non-Income Taxes)
• Consideration of Different Tests and Comfort Levels Used to Reserve or Not

Todd G. Betor, Esq., Partner, Eversheds Sutherland US, New York, NY

Amy Letourneau, Esq., Senior Manager, RSM US, Houston, TX

STATE TAX ADMINISTRATION | 4:00pm – 4:45pm

• Statutes of Limitations
• Requirements of Refund Claims
• Requirements of State Tax Protests of Assessments
  • Differences between Proposed and Final Assessments

Leonore Heavey, Esq., Tax Counsel, Council On State Taxation, Washington, DC

Marilyn Wethekam, Esq., Of Counsel, Council On State Taxation, Washington, DC

Andrew Jay Maschas, Esq., Director, Appeals Division, Comptroller of Maryland, Baltimore, MD