To provide CPAs and other finance professionals with a practical understanding of multistate taxation principles and recent developments, enabling them to evaluate nexus, apportionment, compliance obligations, audit exposure, and planning opportunities affecting businesses operating across multiple jurisdictions.

• Nexus: constitutional foundations and post-Wayfair economic nexus
• Marketplace facilitator laws and economic nexus developments after Wayfair
• Sales and use taxes: economic nexus thresholds and marketplace facilitator laws
• Gross receipts taxes, including the Ohio CAT, Texas Margin Tax, Washington B&O Tax, and Oregon Corporate Activity Tax (CAT)
• Corporate income/franchise tax:
  – Unitary business doctrine
  – Business vs. non-business income
  – Allocation and apportionment
• P.L. 86-272: MTC revised statement and internet activity guidance
• Pass-Through Entity Tax (PTET) elections: post-OBBBA planning
• Financial reporting and state tax provision considerations
• Audit defense
• Planning opportunities

To provide CPAs and other finance professionals with a practical understanding of multistate taxation principles and recent developments, enabling them to evaluate nexus, apportionment, compliance obligations, audit exposure, and planning opportunities affecting businesses operating across multiple jurisdictions.

DETAILED LEARNING OBJECTIVES

• Identify the constitutional limitations that govern a state's authority to impose taxes on multistate businesses

• Distinguish between Due Process Clause requirements and Commerce Clause requirements in state taxation

• Explain the significance of the Quill and Wayfair decisions in the evolution of state tax nexus standards

• Recognize the characteristics of economic nexus provisions adopted by states following Wayfair

• Identify the factors that may establish substantial nexus for state tax purposes

• Differentiate among physical presence nexus, economic nexus, affiliate nexus, and agency nexus theories

• Explain the relevance of key judicial decisions including National Geographic, Scripto, Tyler Pipe, and Geoffrey in nexus determinations

• Describe the additional constitutional considerations applicable under the Foreign Commerce Clause

• Explain the purpose and scope of Public Law 86-272

• Identify activities that qualify as protected solicitation under Public Law 86-272

• Distinguish between protected and unprotected activities under the Supreme Court's decision in Wrigley

• Evaluate the impact of internet-based business activities on Public Law 86-272 protection under current state tax guidance

• Identify common state tax issues associated with drop shipment transactions

• Explain the development of the unitary business principle through major Supreme Court decisions

• Recognize the factors courts use to determine whether a unitary business relationship exists

• Determine when income may be treated as apportionable business income under the unitary business doctrine

• Differentiate between business income and nonbusiness income using both transactional and functional tests

• Explain the purpose of allocation and apportionment methodologies used by states to source multistate income

• Identify current trends in state combined reporting and unitary business group reporting requirements

• Evaluate the impact of recent pass-through entity tax (PTET) developments and federal SALT limitation changes on multistate tax planning considerations

• Nexus: constitutional foundations and post-Wayfair economic nexus
• Marketplace facilitator laws and economic nexus developments after Wayfair
• Sales and use taxes: economic nexus thresholds and marketplace facilitator laws
• Gross receipts taxes, including the Ohio CAT, Texas Margin Tax, Washington B&O Tax, and Oregon Corporate Activity Tax (CAT)
• Corporate income/franchise tax:
  – Unitary business doctrine
  – Business vs. non-business income
  – Allocation and apportionment
• P.L. 86-272: MTC revised statement and internet activity guidance
• Pass-Through Entity Tax (PTET) elections: post-OBBBA planning
• Financial reporting and state tax provision considerations
• Audit defense
• Planning opportunities