Agenda

 Protecting the Bottom Line

Multistate businesses are experiencing flat or declining profits amidst one of the most severe recessions in history. Controlling state income tax costs in these times has never been as important

State income tax cost containment strategies implemented with business purpose coupled with a thorough understanding of today’s tax shelter environments are the subject of a new BNA Portfolio which will be the subject of this presentation.

The presenter, John J. (Jack) Cronin, served as the Partner-in-Charge of Deloitte’s Multistate Tax Practice, prior to his retirement. He will offer practical insights sensitive to the disparate requirements of multiple corporate tax regimes. He will also give some examples of common corporate structure scenarios utilized by retailers and manufacturers in which a taxpayer would likely prevail if challenged by a state tax agency.

Among other things, the Webinar will provide:

•A thorough overview of the doctrines of business purpose and economic substance as applied in the context of multistate taxation;
•A detailed review of state royalty or interest add-back provisions, including the Multistate Tax Commission's Model Add-Back Statute;
•A discussion of state transfer pricing principles, including the application of federal statutory and regulatory provisions establishing arm's-length standards and pricing methodologies;
•Coverage of each state’s tax shelter provisions, including the extent to which each jurisdiction conforms to federal law; and
•Analysis of state voluntary disclosure programs.

What will be covered:

This 90 minute Webinar will provide participants with a conceptual understanding and practical application of the following:
•Analysis of state cases involving the step-transaction doctrine, sham-transaction doctrine, and arguments concerning form versus substance;
•The salient details of state royalty add-back provisions;
•The multistate tax implications of federal statutory and regulatory provisions establishing arm's-length standards and pricing methodologies;
•Federal anti-tax shelter provisions and their adoption into state tax law; and
•The key aspects of each state's voluntary disclosure program.

Education Objectives:

Participants will learn how to:
•Anticipate the legal challenges that a state jurisdiction is likely to make to specific types of tax planning strategies;
•Understand and plan to avoid the application of state add-back statutes;
•Apply federal transfer pricing concepts to the multistate tax planning arena;
•Recognize the different types of federal and state anti-tax shelter regimes, and
•Identify the most important details of a state voluntary disclosure program.