Blank Rome State + Local Tax (“SALT”) partners Craig B. Fields, Eugene J. Gibilaro, and Nicole L. Johnson will serve as panelists at the Council on State Taxation’s (“COST”) 2026 Spring Conference / Audit Session, being held April 20 through 23, 2026, in Coral Gables, Florida. Blank Rome is pleased to be a Diamond Sponsor of the Conference.
About the Program
This Conference will feature presentations on the most recent income and sales tax developments, initiatives, and case law updates, and include breakout sessions that will provide in-depth discussions of specific topics for maximum coverage of the hottest income and sales tax issues. Several state income and sales tax audit sessions (for industry members only) will also be featured, offering a state-by-state exchange of information on legislative, audit, judicial, and regulatory issues affecting COST-member companies.
Session Information
Tuesday, April 21 | 11:10 a.m.–12:05 p.m.
Related-Party Transactions and the Challenges of Addback Statutes
This session will be an intercompany transaction presentation on one of the more complex challenges in state corporate income tax. While addback statutes were initially enacted to counter tax planning strategies, their application has expanded to challenges of all related-party transactions. The panel will discuss the challenges of establishing safe-harbor provisions of the statutes.
- Moderator: Doug Lindholm, COST
- Dan DeJong, KPMG
- Craig Fields, Blank Rome
- Joe Garrett, Deloitte
- Frances Sewell, Pfizer
Tuesday, April 21 | 2:00–2:55 p.m.
Tips for Tax Departments Before, During and After a Merger/Acquisition or Spinoff
Mergers, acquisitions, and spinoffs can create significant opportunities, but they also may bring state tax challenges that must be managed at every stage of the transaction. From due diligence to post-closing integration, tax departments play a critical role in identifying risks, ensuring compliance, and capturing value. This session will provide practical insights into how to manage these transactions.
- Moderator: Michael Carchia, Capital One
- Bill Backstrom, Jones Walker
- Eugene Gibilaro, Blank Rome
Wednesday, April 22 | 3:25–4:20 p.m.
Is It a Fee or a Tax?—And Why It Matters
The distinction between a fee and a tax is more than semantics—it can determine constitutional validity, compliance obligations, and litigationoutcomes. Misclassification can lead to unexpected liabilities, penalties, and even legal challenges. This session will explore the critical differences between fees and taxes, why the classification matters, and how courts and tax authorities draw the line.
- Moderator: Dylan Waits, COST
- Jay Adams, Jones Walker
- Nicole Johnson, Blank Rome
- Bradley Marsh, Greenberg Traurig
- Diane Yetter, YETTER*
For more information and to register, please visit the event webpage.
