State & Local Taxation (SALT) Update Self-Study Webinar

To provide CPAs and tax professionals with an update on the latest developments in state and local taxation. It will focus on income and franchise taxes, sales taxes, property taxes, NEXUS challenges, and other potential tax exposures and deductions.

DETAILED LEARNING OBJECTIVES

• Identify recent state court decisions impacting business vs. non-business income classification

• Describe the scope and limitations of P.L. 86-272 protections for remote sellers

• Evaluate when taxpayer activities exceed the solicitation-only threshold under P.L. 86-272

• Recognize state approaches to taxing marketplace facilitators prior to Wayfair

• Distinguish between business and compensation income in equity sales based on case law

• Explain the impact of repatriation income under the TCJA and related state tax implications

• Compare cost-of-performance and market-based sourcing methods for service revenue

• Apply the UDITPA three-factor formula and understand its limitations in modern economies

• Identify which states have transitioned to single sales factor apportionment

• Analyze sourcing treatment of receipts from sales of services and intangible property

• Determine nexus implications from physical presence, economic thresholds, and remote employees

• Summarize recent legislative developments related to income tax sourcing in key states

• Interpret recent administrative guidance and rule changes in California, New York, and Florida

• Describe the tax treatment and apportionment outcomes in key case decisions such as CMS Energy and Humana MarketPoint

• Identify changes in sourcing rules related to installment sales, goodwill, and digital services

• Explain intermediary transaction rules and their effect on sourcing service revenues

• Assess the apportionment consequences of including or excluding occasional sales and extraordinary events

• Recognize how changes in federal provisions (e.g., Sections 199A, 163(j), 174) affect state taxation

• Understand conformity and non-conformity of states with key TCJA provisions

• Evaluate tax planning strategies including audit preparation, voluntary disclosure agreements, and refund opportunities

• Recent Important Court Cases Impacting SALT
• Restrictions Imposed by Public Law (PL) 86-272
• Nexus
  – Pre-Wayfair
  – Recent fact patterns
  – Troubleshooting
• Income Tax Apportionment for Service Providers
  – Sourcing service revenue
  – Legislative developments
  – Recent administrative guidance
  – Caselaw developments
  – Tax planning takeaways
• Expiring Provisions of the TCJA & the Consequences
  – Qualified business income deduction (Section 199A)
  – Fringe benefits
  – Bonus depreciation
  – Interest expense deductions
  – Research and Development (R&D) expenses
  – Net Operating Loss (NOL) deduction limitation
  – Foreign-Derived Intangible Income (FDII)
  – Global Intangible Low-Taxed Income (GILTI)
  – Like-kind exchanges
  – Dividends received
• State-Specific Updates & Highlights