MultiTax Commission

An intergovernmental state tax agency whose mission is to promote uniform and consistent tax policy and administration among the states, assist taxpayers in achieving compliance with existing tax laws, and advocate for state and local sovereignty in the development of tax policy.

Attorney Training Agenda

Attorney Training and Informational Sharing Session

Monday, July 29, 2024 (all times are Mountain Time)

Sonesta Denver Downtown
1450 Glenarm Place
Denver, Colorado 80202

The attorney training will begin at approximately 10:15 am Denver time, following the conclusion of the meeting of the Litigation Committee meeting.  All sessions are designed to be eligible for CLE credit in most states (unless otherwise indicated). See the MTC’s CLE policy on our website for additional information. 

I. How state revenue departments can address international income shifting?
Two state tax experts will present a case study to help state revenue agency staff and attorneys identify issues and develop responses when multinational companies shift income abroad.
Presenters: Matt Tidwell, Assistant Director, Alabama DOR; Holly Coon, Director of the MTC Joint Audit Program
II. Federal taxation of state tax refunds
When are state tax refunds or rebates taxable to recipients? What are the pitfalls that states should watch out for? Hear from state counsel who have recently interacted with the IRS on this topic which other DOR attorneys may be asked to opine on.
Presenters: Josh Pens, Director of Tax Policy, Colorado DOR; Brendon Reese, Senior Director, Colorado DOR).
III. Appropriate Disclosure of Tax Return Records
Learn what are the key federal and state rules governing the disclosure of tax return information, impact of subpoenas and nondisclosure agreements, and more .
Presenters: Brian Oliner (General Counsel of the FTA); Dana Erlandsen, Chief Counsel, Wisconsin DOR); IRS invited
IV. Use Tax Apportionment?
This session will consider whether there are circumstances when use tax must be apportioned to meet the constitutional requirement of external consistency. It will also consider the sourcing and apportionment rules that apply to electronic transactions.
Presenter: Michael Fatale, General Counsel, Massachusetts DOR
V. When to Appeal a Tax Decision to a Higher Court?
 This panel will discuss the factors to consider when deciding whether to appeal an adverse decision and which issues to bring to the attention of the higher court.
Presenters: Anne Mangiardi, Senior Assistant Attorney General, Colorado; Ray Langenberg, Special Counsel for Tax Litigation, Texas Comptroller of Public Accounts
VI. Generative AI: Chatbots face off against State Tax Attorneys
MTC Senior Counsel Bruce Fort will emcee a head-to-head competition between chatbots and attorney training attendees on a series of SALT topics as a means to assess the quality of AI with respect to state tax. Expect legal analysis by Mr. Fort that will demonstrate that AI still has at least a few things to learn.
VII.

Litigation Roundtable & Information Sharing Session

MTC roundtable discussions provide a forum for public sector tax attorneys to share ideas and seek guidance from colleagues in other states. For this roundtable, we request attendees to submit by COB Wednesday, July. 24 a brief description of any issues or challenges that may benefit from a group discussion. The objective is to generate a group discussion on the issues or challenges, and to discuss possible resolutions or share how those issues or challenges were resolved. We also invite attendees to offer extemporaneous state updates. Please send your discussion ideas to ray.langenberg@cpa.texas.gov or to Brian Hamer.

Attendees should avoid disclosing confidential or privileged tax information. The roundtable will be open to both in-person and virtual attendees. The roundtable is not eligible for CLE credit.

 

Networking Wind Down: This informal gathering will be one of many opportunities to build relationships and share ideas with colleagues.

Dinner: We will walk to a nearby restaurant for those who would like to join a group for dinner.

For additional information, contact MTC Counsel, Brian Hamer.

Back to the 2024 Annual Meetings page.