Under FIN 48, companies have been accounting for uncertain tax positions since 2006. One of the most complicated areas for this is in the calculation of previously unrecognized state and local tax positions.
Building on a series of successful FIN 48 events, The Knowledge Congress is assembling a panel of distinguished professionals and key regulators to help understand the impact of the FIN 48 (state and local tax) for public companies. The speakers will present their expert opinions in a two-hour LIVE Webcast.
Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Group, LLC
Recommended CLE/CPE Hours: 2.0
(Please note, your State Bar or Accounting Board will make the final determination with respect
to continuing education credit.)
Advance Preparation: Print and review course materials
Course Code: 083770
Joe Neff
National Managing Director, State and Local Tax Practice
Jeffrey C. Glickman, Esq.
Partner, State and Local Tax Group
Mark L. Nachbar
Principal
Joe Neff, National Managing Director, State and Local Tax Practice, RSM McGladrey
- Uncertain Tax Positions
- State and Local Taxes Subject to FIN 48 Analysis
- General FIN 48 State Tax Positions
- Filing Decisions
- Nexus Discussion
- State Tax Position on Filed Returns
- Statute of Limitations
- Year 2 Issues
- Application to Flow-Through Entities
- Additional FAS 5 Scrutiny
- FIN 48 Deferral for Private Companies
Mark L. Nachbar, Principalr, Ryan, Inc.
- Nexus
- Characterization of State Taxes. When a state assess tax on an alternative basis, what is considered to be an income tax.
- Statute of Limitation issues
- Disclosure/Discoverability of FIN 48 work papers to state auditors.
Jeffrey C. Glickman, Esq., Partner, State and Local Tax Group, Alston & Bird LLP
- Real World Examples
- Federal uncertain tax positions often have state tax counterparts
- Uncertainty in characterizing income as business or nonbusiness income (e.g., liquidation exception to functional test)
- Uncertainty in application of apportionment rules (e.g., excluding treasury function gross receipts from sales factor, sourcing sales of intangible property under cost of
performance rules, etc.)
- Forced combinations (or de-combinations) - uncertainty as to existence of unitary business
- Intercompany transactions (uncertainty of state tax benefits arising from IP holding company, captive REIT and similar structures, and risks associated with imputed non-tax
driven intercompany transactions)
- CPAs
- CFOs
- Accountants
- State and Local Tax Practice Lawyers
- State and Local Tax specialists
- Tax consultants/managers
- Controllers
- Finance Professionals
- Senior Corporate Officers
This is a must attend event for anyone interested in understanding the State & Local Tax Issues and its impact on public companies.
- New guidance explained by the most qualified key leaders & experts
- Hear directly from key regulators & thought leaders
- Interact directly with panel during Q&A