Blank Rome State + Local Tax partner Eugene J. Gibilaro, of counsel Joshua M. Sivin, and associate Christopher M. Lash will serve as speakers at the Tax Executives Institute (“TEI”) Cincinnati-Columbus Chapter’s SALT Direct Tax Updates, being held Thursday, December 3, 2026, in Cincinnati, Ohio.
About the Program
Eugene, Josh, and Chris will present “SALT Without the Sales Tax: A 2026 Direct Tax Update—Apportionment and Sourcing, Taxation of Foreign Income, Audits, and AI.” The session will be divided into three segments:
State of the States—Income Tax Apportionment and Sourcing Developments for 2026
Most states now source receipts from services and intangibles to the customer’s market rather than to where the work is performed, but the sourcing rules, the remaining cost-of-performance holdouts, and an active docket of apportionment litigation continue to create both risk and opportunity for multistate taxpayers.
State Taxation of Foreign Income After the TCJA and OBBBA
The Tax Cuts and Jobs Act (“TCJA”) moved the federal system from deferral toward current taxation of foreign-source income, and the One Big Beautiful Bill Act’s (“OBBBA”) conversion of global intangible low-taxed income (“GILTI”) into net controlled foreign corporation (“CFC”) tested income (“NCTI”) widens the gap between federal and state treatment. This session examines how states seek to tax foreign-source income, how OBBBA changes can be unfavorable from a state tax perspective, and how taxpayers can press for appropriate apportionment factor representation.
Other Direct Tax Developments, State Audits, and AI
A review of other significant 2025–2026 direct tax developments, followed by a practical walk through the life cycle of a state direct tax audit and a discussion of how artificial intelligence (“AI”) is changing both how states select and conduct audits and how tax departments manage compliance and controversy.
For more and to register, please visit the event webpage.