State Reporting of Federal Changes: Hot Topics and Current Issues

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The final resolution of issues raised during a federal tax audit can trigger consequences at the state level. As a result, multistate businesses must often amend hundreds of state tax returns within a short time frame. The process is often complex and varies from state to state. Jurisdictions differ on matters as basic as what they deem to be a “final determination” at the federal level. The date by which a taxpayer must report a federal change can vary significantly among the states. Filing requirements also differ among the states. Some jurisdictions require a taxpayer to submit full amended return, while other states require a special form.

This practical program will include a discussion of:
• IRS procedures regarding limitations periods, appeals, and refund claims; 
• What constitutes a “final determination” at the federal level for state tax reporting purposes; 
• State time limits for reporting federal changes; 
• State filing requirements for reporting federal changes; 
• The scope of a state’s review upon receiving notice of a federal change; 
• Secondary impacts such as state tax adjustments or the potential for state tax credits or refunds; 
• Practical considerations for filing a protective claim for a refund; 
• Negotiating a filing extension; and 
• Real-life issues and scenarios.

Educational Objectives:
• Distinguish filing deadlines and requirements for reporting federal changes among the states;
• Identify what constitutes a “final determination” and a “federal change” for different states; 
• Determine how filing a federal change can alter state tax liabilities;
• Distinguish between different filing forms associated with federal audits and determine which form is appropriate for protective claims;
• Recall why and how long the statute of limitations may be extended; and
• Recognize common areas of state and federal non-conformity among several tax laws.



Marilyn A. Wethekam is a partner at Horwood Marcus & Berk Chartered and co-chairs the firm's multistate SALT practice. She devotes her practice to state and local taxes on a nationwide basis for multistate and multinational corporations. Marilyn received the Council on State Taxation's 2010 Paul Frankel Excellence in State Taxation Award and the 2012 Bloomberg BNA, Frank Latcham Award for Distinguished Service in State and Local Tax Law.  In 2013, she was named one of the Illinois's Leading Female Attorneys

Marilyn advises her clients on multistate tax issues that involve income, franchise, sales/use and motor fuel taxes. Her eighteen years of corporate tax experience with Mobil Oil Corporation and Montgomery Ward & Co. provide her with an understanding of the complex issues encountered by multistate and multinational corporations.


Fred Nicely serves as Tax Counsel for COST. Fred’s role as Tax Counsel extends to all aspects of the COST mission statement: “to preserve and promote equitable and nondiscriminatory state and local taxation of multijurisdictional business entities.” Before joining COST, Fred served in the Ohio Department of Taxation for four years as Deputy Tax Commissioner over Legal and for the prior seven years as the Department’s Chief Counsel. He is a frequent speaker and author on Ohio’s tax system and on multistate tax issues generally.