32nd Annual

Advanced State & Local Tax Institute

Thursday-Friday, May 14-15, 2009
Georgetown University Law Center Washington, DC
13.5 CLE credit hours (60 minute hour), including 1.0 hour of legal ethics 16.0 CLE credit hours (50 minute hour), including 1.0 hour of legal ethics

SPECIAL SYMPOSIUM
Sourcing the Operations & Transaction of Multijurisdictional Enterprises: A Guide for Tax Planning, Compliance, Policy Making & Enforcement Professionals Wednesday, May 13, 2009

DETAILS INSIDE

Advisory Board & Speakers

Board Chair
Philip M.Tatarowicz Ernst & Young LLP Washington, DC Ronald Lee Grubbs HCA Inc. Nashville,TN Michael Hamersley California Franchise Tax Board Sacramento, CA Rick Handel South Carolina Department of Revenue Columbia, SC Ann Holley KPMG LLP Washington, DC Joe Huddleston Multistate Tax Commission Washington, DC Stephanie Anne Lipinski Galland Thompson Coburn LLP Washington, DC Michael H. Lippman Alvarez & Marsal Taxand, LLP Vienna,VA Patrice Mano Deloitte Tax LLP San Francisco, CA Robin Maxwell Ernst & Young LLP New York, NY Sarah McGahan KPMG LLP Washington, DC J. Alexander Meleney Deloitte Tax LLP Washington, DC Roberta Mossley Nero Morrison & Foerster LLP New York, NY Jon Muroff PricewaterhouseCoopers Boston, MA Walter Nagel Sullivan & Worcester LLP Washington, DC Sarah Hedman OLeary Ohio Department of Revenue Columbus, OH Kathleen King Parker Pierce Atwood Boston, MA Prof. Richard D. Pomp University of Connecticut School of Law Hartford, CT Rich Prem Amazon Seattle, WA Scott G. Roberti General Electric Company Stanford, CT Carley A. Roberts Morrison & Foerster LLP Sacramento, CA Arthur R. Rosen McDermott Will & Emery New York, NY Michael H. Salama The Walt Disney Company Burbank, CA Shirley K. Sicilian Multistate Tax Commission Washington, DC Amy Silverstein Silverstein & Pomerantz San Francisco, CA Brian J. Sullivan Deloitte Tax LLP Atlanta, GA James P Sweeney . Attorney At Law East Brunswick, NJ Daniel J.Thibault Ernst & Young LLP Minneapolis, MN Brandee Tilman The Walt Disney Company Burbank, CA William D.Townsend Fowler White Boggs Banker Tallahassee, FL Stewart M.Weintraub Schnader Harrison Segal & Lewis LLP Philadelphia, PA Marilyn A.Wethekam Horwood Marcus & Berk Chartered Chicago, IL Ken Zemsky Ernst & Young LLP New York, NY Philip M. Zinn PricewaterhouseCoopers LLP New York, NY

Program Details
Hotel Reservations A block of rooms has been held at the following two hotels until April 10, 2009. These rooms will be held as a block, unless exhausted, until the above date at which time they will be released to the general public. Please mention Georgetown State & Local Tax when making reservations to receive the special rates. Option 1 The Phoenix Park Hotel 520 North Capitol Street NW Washington DC 20001 1-800-824-5419 or 202-638-6900 Group Name - Georgetown State & Local Tax http://www.phoenixparkhotel.com/reztrack.html Online: Group Code 12863 Room rate: $289 single Option 2 The Liaison, Capitol Hill 415 New Jersey Ave NW Washington DC 20001 1-866-233-4642 Group Name - Georgetown State & Local Tax reservations@affinia.com Room rate: $299 single/double Disclaimer Speakers are subject to change. Services for People with special needs or dietary restrictions Call (202) 662-9890 Scholarships Georgetown Law CLE makes every effort possible to provide equal educational opportunities to all. We provide a limited number of scholarships on a case-bycase basis. Apply online at www.georgetowncle.org or submit written request no later than 5:00 pm on Thursday, April 30, 2009 to: Scholarship Committee Georgetown Law CLE 600 New Jersey Avenue, NW Washington, DC 20001 or fax to (202) 662-9891 Cancellations/Rain Checks/Substitutions Please fax your cancellation notice to (202) 662-9891 by 5:00 pm on Monday, May 11, 2009 for a refund (less $75 administrative fee). Rain checks for a future program will be granted for cancellations received after May 11 and prior to the start of the program. Substitutions are accepted at anytime prior to the program. Money-Back Guarantee We are confident that you will leave this conference with more than enough ideas and insights to make your investment pay off. However, if you feel you have not received your moneys worth by the end of the program, simply contact a member of our registration team at the conference or call (202) 662-9890 and we will process a 100% refund for your registration fee! CLE Credits Accreditation has been or will be requested for this program from states with mandatory Continuing Legal Education requirements for 13.5 CLE credits (based on a 60 minute hour), including 1.0 hours of legal ethics and 16.0 CLE credits (based on a 50 minute hour), including 1.0 hours of legal ethics. Georgetown University Law Center is an accredited CLE provider in most MCLE states. Georgetown Law CLE is a State Bar of California approved MCLE provider. Some states require nominal accreditation fees. You will be asked to submit payment at the programs conclusion. CPE Credits Georgetown Law CLE is registered with the National Association of State Board of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville,TN, 37219-2417. Web site: www.nasba.org. Course level: Overview; Group-Live, no prerequisites or advance preparation required.

Speakers & Board Members

Robert J. Buckley United Technologies Corp. Farmington, CT Bobby L. Burgner General Electric Company Atlanta, GA Stephen M. Cordi DC Office of Tax & Revenue Washington, DC Nicole Crighton KPMG LLP Washington, DC Joe Crosby Council on State Taxation Washington, DC Keith W. Davis Bank of America Corporation Charlotte, NC Francina A. Dlouhy Baker & Davis LLP Indianapolis, IN James R. Eads, Jr. Federation of Tax Administrators Washington, DC Peter L. Faber McDermott Will & Emery LLP New York, NY Craig B. Fields Morrison & Forrester LLP New York, NY Paul H. Frankel Morrison & Foerster LLP New York, NY Lynn A. Gandhi Honigman Miller Schwartz & Cohn LLP Detroit, MI Virginia A. Gates PricewaterhouseCoopers LLP Chicago, IL Jerrold S. Gattegno Deloitte Tax LLP Washington, DC Jordan M. Goodman Horwood Marcus & Berk Chartered Chicago, IL

Southeast - Alabama, District of Columbia, Florida, Georgia, Kentucky, Maryland, Mississippi, North Carolina, South Carolina,Tennessee,Virginia, West Virginia William D. Townsend

Agenda
Thursday, May 14
n 7:30-8:15 am Registration & Continental Breakfast n 8:15-8:30 am Introduction & Overview Philip M.Tatarowicz n 8:30-9:15 am Current Developments: A Nationwide Perspective Daniel J.Thibault Discussion and analysis of the years most important state and local corporate income tax developments on constitutional, legislative, administrative and judicial levels. n 9:15-10:00 am State Taxation of Troubled Companies J. Alexander Meleney Discussion of various state tax issues that arise when dealing with bankrupt and insolvent companies, including the impact of cancellation of indebtedness, and limits on utilization of net operating losses. Session will focus on differences in how the states apply IRC 108 and 382 to corporate groups when the federal consolidated return regulations do not apply. n 10:00-10:30 am Networking Break n 10:3011:15 am What Will Conversion from U.S. GAAP to IFRS do for Financial Accounting & What Issues & Opportunities Will It Afford Taxpayers & Tax Administrators? Virginia A. Gates Patrice Mano The conversion to IFRS has the potential to impact many facets of state and local income and non-income taxation, including the starting point for calculating federal taxable income and various gross receipts tax bases. Further, the revaluation of property to fair market value under IFRS may impact apportionment factors, capital net worth tax computations and property tax valuations. Will the IRS accept or reject IFRS as a starting point? Will the states adopt IFRS or decouple? Our distinguished panel will identify the issues and opportunities, as well as offer their views of who might win or lose as the state tax ramifications of conversion to IFRS unfold. n 11:15 am-12:00 pm Does Substantial Nexus Include Nano Nexus? Moderator: Walter Nagel Panelists: Shirley K. Sicilian James R. Eads, Jr. Arthur R. Rosen Stewart M. Weintraub Multistate taxpayers have a far reaching ability to approach the national market place. Yet this reach is often through third or non-traditional parties. Just how little nexus is required to be subject to state income tax? n 12:00-12:30 pm Box Lunch Distribution n 12:30 1:30 pm Breakout Sessions: Regional Discussions Each regional discussion will be co-facilitated by a state general counsel from the appropriate region. Northeast - Connecticut, Delaware, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island,Vermont Kathleen King Parker

Central - Arkansas, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska, North Dakota, Ohio, South Dakota, Wisconsin Jordan M. Goodman West - Alaska, Arizona, California, Colorado, Hawaii, Idaho, Louisiana, Montana, Nevada, New Mexico, Oklahoma, Oregon,Texas, Utah, Washington, Wyoming James P. Sweeney n 1:30-1:45 pm Networking Break n 1:45-2:45 pm New Forms of Coercion or Influence The Legal Ethics of Penalties Imposed on Taxpayers & Third Party Intermediaries Carley A. Roberts Brandee Tilman Do steep, arbitrary, automatic and amnesty spawned penalties violate due process, manifest justice and square corners? Should a state be able to say, Pay your disputed taxes, well waive penalties and interest or face the consequences, i.e. a new harsh penalty that wasnt part of the law when the return was filed? n 2:45-3:30 pm Taxation of Financial Instruments Ann Holley The worldwide economic slowdown and credit crisis have raised the need to better understand the state and local tax principles and issues as they relate to the taxation of financial instruments. This session will review the basic principles involved in the taxation of financial instruments with emphasis on recent developments. Topics to be discussed include the characterization of certain losses as ordinary or capital losses, business versus non-business issues, treatment of financial instruments in the apportionment factors, dealing with write-offs of certain types of debt and nonperforming assets, and the combination issues that arise in groups involving finance-related firms. n 3:30-4:00 pm Networking Break

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n 3:45-4:45 pm A Non-Confrontational Colloquy between Taxpayers & Select State Tax General Counsels Moderator: Marilyn A. Wethekam Panelists: Rick Handel State general counsels to be announced At this always lively session, state general counsels will discuss their perspectives of current state tax issues. Institute participants will have the opportunity to submit questions by emailing cle@law. georgetown.edu prior to the session for response by the general counsels. n 4:45-5:30 pm Business Purpose & Economic Substance in State Taxation Peter L. Faber Michael Hamersley This session will explore the meaning of these concepts in the state tax arena, including their impact on state tax planning and reorganizations from both the government and taxpayer perspective. n 5:30-7:00 pm Networking Cocktail Reception Sponsored by BNA Tax Management

Value Added Taxes levied by other nations share many of the same concepts seen within sales and use taxes, albeit at rates (risks and opportunities) that are often four times as high. Not surprisingly, then, sales and use tax specialists may be able to contribute to and/or coordinate a taxpayers global VAT compliance obligations and planning strategies in this area. This session will highlight how VAT concepts compare with sales and use taxes. Through examples, it will inform where VAT opportunities and risks present themselves and how knowledgeable sales and use tax persons can best position themselves to make significant contributions. n 10:00-10:15 am Networking Break n 10:15-11:00 am Implementation & Administrative Issues in Administering Gross Receipts Taxes; Perspectives from State Administrators & Taxpayers Moderator: Philip M. Zinn Panelists: Sarah Hedman OLeary Francina A. Dlouhy Lynn A. Gandhi This panel will review the current trend towards adoption of gross receipts, net worth and hybrid taxes, and the implementation and administration issues faced by both revenue departments and corporate taxpayers in understanding, adopting and implementing the necessary tools and processes to timely comply with reporting requirements. They will also consider the issues of why certain states repealed their gross receipts taxes and discuss whether these non-income taxes will live up to their promised benefits. n 11:00-11:45 am New York Sales Tax Nexus Moderator: Stephanie Anne Lipinski Galland Panelists: Craig B. Fields Rich Prem Does New Yorks Amazon Law stretch the boundaries of the U.S. Constitutions nexus standards? Is this a trend or just an anomaly? This panel will discuss the new agency nexus concepts and the impact these concepts may have on both business operations and state revenues. n 11:45 am-1:15 pm Lunch (on your own) n 1:15-2:00 pm Looming Implications for the Nation, States & Taxpayers Arising Out of the

Growing Push For Fundamental Federal & State Tax Reform Joe Crosby Scott G. Roberti This session will review the existing federal legislation and what consequences lie in wait for all parties if the legislation is signed into law. The session will also look at the consequences of state reforms and third party initiatives such as NCCUSL and voter referendums. n 2:00-2:45 pm Panel on State Tax Litigation Strategy Nicole Crighton Roberta Mossley Nero Amy Silverstein Ken Zemsky Tax litigation involves the assessment and selection of procedural and substantive strategies from the initial stages of an examination through the decision whether to appeal an adverse decision to the U.S. Supreme Court. This panel will focus on current, cutting-edge cases and evaluate the success or failure of strategies pursued throughout various stages of the litigation with the objective of identifying best practices and poor choices. n 2:45-3:00 pm Networking Break n 3:00-3:45 pm Ten Common State Tax Traps for the Unwary in the Area of Mergers & Acquisitions Jon Muroff Brian J. Sullivan This discussion will focus on the opportunities and traps at the state level related to I.R.C. Section 338 elections, the acquisition and disposition of loss companies, non-income tax considerations, and key state differences from federal tax in such areas as basis of subsidiary stock, earnings and profits, distributions, excess loss accounts, and deferred intercompany stock accounts. n 3:45-4:30 pm Current Audit Issues Outside the Sales & Use Tax Area Paul H. Frankel Prof. Richard D. Pomp Nationally respected commentators will discuss trends and developments outside the sales and use tax area, including recently decided, current and ongoing issues being challenged by state and local tax commissions from the viewpoints of the taxpayer and the state. Also, as a special bonus feature of this years program, our commentators will analyze what it takes to be a loser at all steps of a tax dispute!

Friday, May 15
n 7:45-8:15 am Continental Breakfast n 8:15-8:30 am Introduction & Overview Stephen M. Cordi n 8:30-9:15 am Sales & Use Taxes: Current Developments - National Perspective Sarah McGahan A review of recent constitutional, legislative, judicial and administrative sales and use tax developments with an emphasis on those developments giving rise to planning and refund opportunities. n 9:15-10:00 am Value Added Tax Compliance & Planning: Have You Talked to Your Sales & Use Tax Specialists? Robert J. Buckley Robin Maxwell

town Law CLE courses online through West LegalEdcenter. r website at www.georgetowncle.org.

SPECIAL SYMPOSIUM
5th Annual Symposium

Sourcing the Operations & Transaction of Multijurisdictional Enterprises: A Guide for Tax Planning, Compliance, Policy Making & Enforcement Professionals
Presented by Georgetown University Law Center CLE & the American Bar Association Tax Sections State & Local Tax Committee

Wednesday, May 13, 2009

Agenda
n 7:30-8:15 am Registration & Continental Breakfast n 8:15-8:40 am Welcome & Opening Remarks Kimberley M. Reeder Lawrence J. Center

At the recommendation of the State and Local Tax Committee of the ABA, the National Conference of Commissioners on Uniform State Laws (NCCUSL) developed a corporate income sourcing regime that was principally designed to deal with manufacturing and mercantile entities. This session will outline the sourcing rules embodied within UDITPA. Also, it will review how UDITPA has informed and empowered the States in their adoption of sourcing rules aimed at specialized industries such as airlines, construction contracting, railroads, trucking, television and broadcasting, publishing, telecommunications, and financial institutions. n 11:00-11:40 am Sourcing Receipts from the Disposition of Financial Instruments Dr. Charles E. McLure, Jr. Recent developments and challenges in California (e.g., Microsoft v. FTB and GM v. FTB) and other states have brought into better focus the effects that the treatment of receipts from the disposition of financial instruments can have on the sales factor. In this session a preeminent scholar presents what will no doubt be viewed by many as the most thorough analysis ever undertaken of this important topic. n 11:40 am-12:00 pm Box Lunch Distribution n 12:00-1:30 pm Illustrative Issues Spawned From the Policy Choices Embodied Within UDITPA Theodore R. Bots Maureen Pechacek Patrick Smith UDITPA raises numerous issues for those responsible for tax compliance, enforcement and planning. In this session our three-person panel of noted practitioners will address, respectively, one issue as it relates to each of the three factors prescribed by UDITPA. The payroll factor: Whose factor is it anyway? The property factor: Should intangibles be taken into account? The sales factor: The sticky issues arising out of the sourcing of receipts from services and intangibles from other than financial instruments n 1:30-1:40 pm Networking Break n 1:40-2:20 pm Should UDITPA Be Revisited?: A Point & Counterpoint Joe Huddleston Stephen P. Kranz Since NCCUSL announced its intention to re-examine UDITPA a robust debate has emerged over the value of this course of action. On the one hand the Multistate Tax Commission (MTC) and representatives from many State Departments of Revenue have strongly voiced their support for this re-examination and have listed the order of priority in which they would like to see changes made. At the

Doctrines,Tensions, Options & Issues

n 8:40-9:20 am Domicile versus Source Based Taxation: Must One Define the Other? Todd A. Lard Sourcing rules that result in extraterritorial taxation are suspect, yet the courts have upheld sourcing regimes that assign extraterritorial activities to the domiciliary state. This session will explore federal law limitations on the powers of the states to tax extraterritorial values. It will explore the tensions between residency and source based theories of taxation and, then, juxtapose how this tension influences other tax policy decisions. For example, does federal law require that a state assert its jurisdiction based upon the activities of the investor and/or the investee within its boarders? Is the only linchpin of apportionability the unitary business doctrine or has the U.S. Supreme Court come to recognize others? Should the answers to these questions vary depending upon the type of tax levied? To what extent and under what circumstances can hybrid approaches be employed? n 9:20-10:00 am An Overview & Discussion of the Pros and Cons of Differing Transfer Pricing Methodologies & The Sourcing Options Available to Tax Policy Makers Prof. Tracy A. Kaye Joann M. Weiner Absent worldwide group reporting, transfer pricing laws are needed to assure that members of a multijurisdictional group properly report their aliquot share of that related groups combined taxable values. Once taxable values are properly attributed to the reporting taxpayer (be it a separate entity or group of entities), various sourcing options exist to assure that taxpayers properly report that portion of their multijurisdictional values deemed attributable to the taxing jurisdiction. From a high level, an economist will discuss transfer pricing methodologies and the challenges they must address. A legal scholar will outline the different approaches available to tax policy makers in sourcing multijurisdictional values. On a comparative law basis, the methodologies employed by the States will be contrasted to the sourcing rules found in the Internal Revenue Code and other select non-U.S. jurisdictions. Once detailed, this distinguished panel will contrast the pros and cons of each sourcing system including their related compliance costs and risks, as well as the planning opportunities afforded by each. n 10:00-10:20 am Networking Break

Speakers

Theodore R. Bots Baker & McKenzie LLP Chicago, IL Joe Huddleston Multistate Tax Commission Washington, DC Hollis L. Hyans Morrison & Foerster LLP New York, NY

Carl Joseph FTB Multistate Bureau Sacramento, CA Prof.Tracy A. Kaye Seton Hall Law School South Orange, NJ Stephen P. Kranz Sutherland Washington, DC

Corporate Income & Illustrative Challenges

n 10:2011:00 am An Overview of UDITPA & the Alternate Regimes that Have Been Adopted to Deal with Specialized Industries Allyson A. Pyrdek

top of the MTC list is UDITPA Section 17 that proscribes an income producing activities test measured by costs of performance for sourcing sales from other than tangible personal property attributable to more than one state. By comparison, many large multijurisdictional taxpayers, along with the Council on State Taxation and the Tax Executives Institute, among others, have stood strongly as opponents.

Conceptual & Practical Challenges

n 2:20-3:00 pm When Is Symmetry between the Tax Base & Sourcing Rules Required? Hollis L. Hyans The cry for no taxation without factor representation has been heard many times over the years, yet the courts are far from clear under what circumstances such is required by Federal law. This session will contrast and analyze the rulings of various tax tribunals, across a spectrum of differing levies, to aid one in better focusing and understanding when and to what degree the law requires symmetry between the tax base and sourcing rules adopted by any given state. n 3:00-3:40 pm Avoiding Apportionment Frustrations & Pitfalls Carl Joseph Jonathan Liss In this session a taxpayer and state representative will discuss the common apportionment frustrations and pitfalls faced by companies. The taxpayer representative will offer advice on how to ameliorate common frustrations and manage administrative burdens. The state representative will provide insights into unique apportionment issues and how to steer clear of potential pitfalls, at least in some states. n 3:40-4:00 pm Networking Break n 4:00-4:40 pm Per Se versus Applicational Challenges: Use of Alternative Apportionment Provisions Carolyn Joy Lee Charolette F. Noel Given the complex business models existing in our current economy it is not surprising that application of standard apportionment provisions often fail to yield a result that provides a fair reflection of business conducted in the state. This session will explore the difficulties in challenging the fairness of an apportionment formula on a per se basis. Further, it will examine UDIPTA Section 18 and the situations where the states have allowed or required a taxpayer to utilize an alternative apportionment formula.

Closing Observations & Comments

n 4:40-5:20 pm Whats Working & Whats Not Ferdinand P. (Andy) Schoettle, LL.D. Ph.D. This concluding session will explore formulary apportionment issues in the aggregate and identify areas that seem to be working for both taxpayers and states, and areas that are more troublesome. Comments will also be offered on how the sourcing rules of the states could be revised to alleviate some concerns. n 5:20-5:30 Concluding Remarks

Speakers

Todd A. Lard Council on State Taxation Washington, DC Carolyn Joy Lee Jones Day New York, NY Jonathan Liss Rohm & Hass Philadelphia, PA

Dr. Charles E. McLure, Jr. Stanford University Palo Alto, CA Charolette F. Noel Jones Day Dallas, TX Maureen Pechacek PricewaterhouseCoopers LLP San Diego, CA

Allison A. Pyrdek KPMG San Francisco, CA Ferdinand P. (Andy) Schoettle, LL.D. Ph.D. George Mason University at Law School Fairfax, VA

Patrick H. Smith Ernst & Young LLP Washington, DC Joann M. Weiner Contributing Editor Tax Analysis Falls Church, VA

Registration Form
PLEASE PRINT OR TYPE. Payment must accompany registration.

Advanced State & Local Tax Institute (May 14-15) Early-Bird Registrations must be received before April 10, 2009 o $995 Early-Bird Regular Registration o $945 Early-Bird Georgetown Law Alumnus class of o $1095 Regular Registration o $1045 Georgetown Law Alumnus class of o $495 Government Registration Course Materials Please select in which format you prefer to receive your course materials. o Hard copy book o CD-ROM o $50 for both hard copy book and CD-ROM Registrants not selecting a desired format will receive their materials based on format availability. Multijurisdictional Enterprises (May 13) o $395 Registration o $195 Government Registration Registrants for the Multijurisdictional Enterprises symposium will receive course materials as a hard copy book. Name: o Mr. o Ms. Email address: (please print clearly) Firm/Organization: Address: City: Phone: ( Fax: ( ) o Yes o No What state(s)? ) State: Zip:

CLE credit?

Your priority code is: Help us expedite your registration! Enter the characters appearing on the top of the mailing label. Please enter this code even if the label is addressed to someone else. Thank you! I cannot attend, but send me: o Hard Copy Course Materials $199 o CD-ROM Course Materials (text only) $199 o Audio CD-ROM Course Materials (audio & text) $499 For CD-ROM and course material, individuals or firms with a DC address should add 5.75% sales tax, VA 5.0%, MD 6.0%, NY 4.0% and PA 6.0% (or 7.0% if from Philadelphia or Allegheny County.) FOUR WAYS TO REGISTER: 1. ONLINE www.georgetowncle.org 2. MAIL with check payable to Georgetown Law CLE to address below. Check enclosed # or purchase order may be attached to this form # 3. FAX to (202) 662-9891 (credit card/PO registrations only) o VISA o MC o AMEX Card #: Expiration Date: Signature: 4. PHONE to (202) 662-9890 (credit card registrations only) Georgetown University Law Center Continuing Legal Education 600 New Jersey Avenue, NW Washington, DC 20001-2075 $

32nd Annual

Advanced State & Local Tax Institute

Thursday-Friday, May 14-15, 2009
Georgetown University Law Center Washington, DC

Georgetown University Law Center Continuing Legal Education 600 New Jersey Avenue, NW Washington, DC 20001-2075

Non-Profit U.S. Postage PAID Wash., D.C. No. 3493

SPECIAL SYMPOSIUM
Sourcing the Operations & Transaction of Multijurisdictional Enterprises Wednesday, May 13, 2009
Attention Mail Room: If the individual whose name is on the label is no longer employed, please forward this material to the successor.

At the 2009 Advanced SALT Institute You Will:

n Review the years most important state and local corporate income tax developments from a nationwide perspective n Receive updates on the key issues and cases at the state level during our popular regional lunch breakout discussions n Obtain balanced perspectives on critical issues from academics, state general counsels and corporate taxpayer experts n Explore a myriad of state tax issues that arise when dealing with bankrupt and insolvent companies n Assess the issues and opportunities arising from the conversion from U.S. GAAP to the IFRS n Learn about the top priorities facing state general counsels and send them your questions in advance n Enjoy the annual and entertaining debate on current audit issues throughout the country between Professor Richard Pomp and Paul Frankel n Learn and network with state general counsels, who have been invited from all 50 states

Whats New at the 2009 Institute?

n Analyze how little nexus is required for multistate taxpayers to be subject to state income tax n Explore the ethics of penalties imposed on taxpayers and third party intermediaries n Assess the principles behind the taxation of financial instruments in light of the economic slowdown n Examine the meaning of business purpose and economic substance in state taxation, including the impact on state tax planning and reorganizations n Learn how VAT concepts compare with sales and use taxes and how sales and use tax specialists can contribute to VAT compliance and planning n Review the current trend toward the adoption of gross receipts, net worth and hybrid taxes, as well as their administrative and implementation issues n Analyze best practices in state tax litigation strategy n Identify common state tax traps for the unwary in the area of M&A

About Georgetown Law CLE

Georgetown Law CLE has established a thirty-two year tradition providing the legal community high quality programs. Our programs are developed with the professions ever-changing needs in mind, while at the same time meeting the mandatory CLE requirements of various state bars. Located in the heart of the nations capital, we feature the countrys leading officials, judges and practitioners.