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International Provisions of Tax Cuts and Jobs Act in a State Context

Venue

This is a virtual event, accessible over the phone. Access instructions will be provided after registration.

Description

In response to Tax Cuts and Jobs Act’s Transition Tax, GILTI and other foreign income provisions, state governments have taken radically different positions on how such income is taxed on the state level. While some states exclude most or all foreign income, others are taxing a huge swath of it. To add to the complexity, some states have not yet decided how to treat this type of income. Hear from our speakers on how to turn this complicated situation into opportunities for sophisticated tax planning.  

Educational Objectives:

• Get an update on the complex map of state tax conformity with federal provisions: especially GILTI, Section 965, FDII and others
• Understand the impact of TCJA provisions on state income/franchise taxes
• Learn how the Foreign Commerce Clause limit state conformity to TCJA international tax rules
• Hear discussion of the constitutionality of state taxation of GILTI

Who would benefit most from attending this program?

• Corporate tax professionals
• Corporate Tax Attorney/Counsel, Controller/Comptroller, CPA/Accountant, General Counsel
 

Presenters

Scott Brian Clark
  • Partner
  • Dentons US

Scott Clark is a partner and senior member of the Dentons’ US tax team and serves as the Chair of the firm’s National Multi-State Tax Services Practice.  For more than thirty years Mr. Clark has been at the forefront of the state and local tax world.  He is well-versed in the intricacies of state tax planning, audits, and tax litigation in most all of the 50 states.  He has handled a wide variety of cases and issues for both ultra-high net-worth individuals, prominent entertainers & personalities, and significant U.S. and multi-national corporations, particularly those focused on e-commerce, communications, technology and retail.  Over the years, Mr. Clark has been involved in a multitude of high-stakes tax audits and certain of the most significant cutting-edge state tax matters all across the country.

Prior to joining private law practice, in the late 1990’s Mr. Clark was a Partner and co-leader of PricewaterhouseCoopers’ national multistate tax and legal services (TLS) “Communications” Practice.  Earlier he served for many years as the Associate Tax Counsel for the GTE Corporation (now Verizon).  He began his career in the public accounting world with Deloitte, Haskins & Sells and Coopers & Lybrand.  He is an active member of the Bar in several states including New York, Connecticut, Washington D.C., and Florida.

William Pardue
  • Principal, State Income and Franchise Tax
  • Ryan

William Pardue, Esq. is a Principal at Ryan, LLC in the State Income and Franchise Tax (SIFT) practice. Mr. Pardue has more than 11 years of experience specializing in providing state and local tax solutions throughout the nation to clients in a range of industries, including technology, consumer products, manufacturing, hospitality, and financial services.

Mr. Pardue concentrates his practice on helping clients achieve their business goals in an advantageous state and local tax manner. In accomplishing this goal, Mr. Pardue has assisted clients in reducing their effective tax rate through the utilization of alternative apportionment, proper sourcing, reduction of throwback, application of credits and incentives, and proper group filing methodologies. Additionally, Mr. Pardue has extensive controversy experience in state and local tax matters at the audit, administrative, and judicial levels. His clients have included established Fortune 500 publicly traded companies as well as companies in their start-up phase.

Mr. Pardue also assists clients with the state and local tax issues inherent in expanding operations to new jurisdictions, opening new business lines, and mergers and acquisition.

Mr. Pardue earned a Bachelor of Science in Business Administration from the Kenan-Flagler Business School at the University of North Carolina at Chapel Hill and a Juris Doctorate degree from the University of Miami School of Law, where he was the Editor-in-Chief of the Psychology, Public Policy & Law Journal.

Jared Walczak
  • Director of State Tax Policy
  • Tax Foundation

Jared Walczak is Director of State Tax Policy with the Center for State Tax Policy at the Tax Foundation. He is the lead researcher on the annual State Business Tax Climate Index and Location Matters, and previously authored or coauthored tax reform books on Iowa, Louisiana, Nevada, Pennsylvania, and South Carolina.

Jared’s work has been cited by The New York Times, The Wall Street Journal, The Washington Post, Los Angeles Times, Politico, AP, and many other prominent national and state outlets. He previously served as legislative director to a member of the Senate of Virginia and as policy director for a statewide campaign, and consulted on research and policy development for a number of candidates and elected officials.

Steven Wlodychak
  • Principal
  • Ernst & Young

Steve Wlodychak is the State and Local Tax Leader for the EY’s Americas Tax Policy in Washington, DC. He previously worked in the EY Los Angeles and New York offices, was a state and local tax attorney for an international insurance company and an associate attorney with a major regional law firm. He previously worked in state government in New Jersey, including for the governor of the state. He focuses his practice on the state and local tax aspects of mergers and acquisitions. A frequent speaker and writer on state and local tax developments, with Bruce Ely of the multistate law firm of Bradley Arant Boult Cummings LLP, Steve received the Bloomberg Tax & Accounting State Tax Co-Author of the Year award in December 2017 for their work on Bloomberg Tax’s Pass-through Entity Navigator (PTEN). Earlier that year, EY also awarded Steve its first ever lifetime achievement award as tax educator of the year. Steve holds degrees from Georgetown University’s School of Foreign Service, Seton Hall University School of Law and a master’s degree in tax law from New York University School of Law.

Moderator: Sahel Ahyaie Assar
  • International Tax Counsel
  • Buchanan, Ingersoll & Rooney

Ms. Sahel Ahyaie Assar is International Tax Counsel at the law firm of Buchanan, Ingersoll & Rooney in Washington, DC. She is a graduate of American University Washington College of Law (JD) and holds two master of laws (LL.M.) from the Georgetown University Law Center in Tax and Securities Regulations. Ms. Assar’s practice is focused on U.S. international tax law, including inbound and outbound transactions. She is the author of numerous articles on international tax law and taxation of cryptocurrencies. In addition to her current legal practice, Ms. Assar’s past professional experiences include working for a large Swiss financial institution and KPMG, Washington National Tax. Ms. Assar is a regular speaker at events and seminars.

Continuing Education

Credits:
1.2 CPE, 1.0 General COA, 1.2 CLE
Practice Areas:
Practice Area: Taxes
Level:
Basic
Production Date:
01/06/2020