Speaking Engagement

COST 2024 Spring Conference & Audit Session

Council on State Taxation

Hyatt Regency Boston/Cambridge
575 Memorial Dr
Cambridge, MA 02139

Blank Rome State + Local Tax (“SALT”) partners Nicole L. Johnson, Mitchell A. Newmark, and Craig B. Fields will serve as speakers at the Council on State Taxation’s (“COST”) 2024 Spring Conference & Audit Session, being held April 30 through May 3, 2024, in Cambridge, Massachusetts. 


This three-and-a-half-day conference will bring multistate tax professionals, with various levels of experience in state and local income/franchise taxes and sales/use taxes together in an environment that allows for extensive interaction and exchange of information as well as updates on key SALT issues and insights regarding state tax trends and opportunities. The program is targeted to all levels of experience and no advance preparation is needed.


Nicole Johnson: “SALT in the Wound”
Wednesday, May 1, from 10:15 to 11:10 a.m.

States continue to test the constitutional limitations on their taxing authority and are sometimes successful in doing so. The panel will discuss the pivotal cases and the application of those decisions by the states to expand their reach to impose their taxes. Specifically, the application of cases covering sales factor apportionment (Moorman), separate geographic accounting (Butler Brothers), worldwide combined reporting (Container, Barclays), sales tax on services (Goldberg, Jefferson Lines), and nexus (Wayfair) will be discussed. Additionally, the panel will address the future of Complete Auto Transit’s dormant Commerce Clause restriction on state taxation.

Mitchell Newmark: “Big Gain Hunting”
Wednesday, May 1, from 4:00 to 4:50 p.m.

The apportionment and taxation of non-reoccurring gains from one-time transactions continues to evolve, pushing the boundaries of the external consistency test and extraterritorial taxation. This session will discuss the evolution of apportionment theories including the use of investee apportionment to source gains.

Craig Fields: “Combined Reporting Issues”
Thursday, May 2, from 1:20 to 2:10 p.m.

Among the many issues an affiliated group of corporations has to face when filing a combined report is the varied, and ever-changing, treatments states impose on foreign affiliates and 80/20 companies within the group. This presentation will review the global reach of state unitary tax regimes with an in-depth look at different states’ approaches to the 80/20 rule treatment of foreign income and any potential relief from double taxation that may result from that treatment.

For more information and to register, please visit the event webpage.