Speeches & Publications

SPEECHES

State Tax Implications of Pillar Two for Multinational Companies, COST Annual Meeting (Sept 2024)

Pillar 2 & the States, Tax Analysts Webinar (April 2024) (https://events.taxanalysts.org/tawebinar042424)

International Businesses and the State Tax Twist, ABA-IPT Income Tax Symposium (March 2024)

Foreign Country Taxation and US SALT – Governments Working Off the Same Playbook, COST Annual Meeting (Oct 2023)

Hot Topics and New Developments in SALT, Michigan State Bar Tax Section Annual Conference (May 2023)

International Issues in SALT, ABA/IPT Income Tax Symposium (March 2023)

Ever-Expanding Combinations, New England SALT Forum (Nov 2019)

 Refund Claim Roadblocks – How to Get Past Them, TEI-NJ Chapter (Feb 2019)

 Market Sourcing, Hartman State & Local Tax Forum (Oct 2018)

 Refund Claims: A Nationwide Survey, IPT Sales Tax Symposium (Sept 2018)

 Related Party Transactions, IPT Advanced State Income Tax School (May 2018)

 Taxpayer Remedies, IPT Advanced State Income Tax School (May 2018)

 Refund Roadblocks & How to Jump Them, Hartman State & Local Tax Forum (Nov 2017)

 Pursuing Indirect Tax Refund Claims, COST Annual Meeting (Oct 2017)

 Son of Quill: The Sequel, IPT Sales Tax Symposium (Sept 2017)

 State & Local Taxation of Partnerships, NYU Summer SALT Institute (July 2017)

 Passthrough Entities, IPT Advanced State Income Tax School (June 2017)

 Taxation of Foreign Affiliates, IPT Advanced State Income Tax School (June 2017)

 E-Commerce Income Tax and Sales Tax Issues, PLI State Tax Seminar (March 2017)

 East Coast vs. West Coast – “In House” vs. “Out House,” ABA-IPT Sales Tax (March 2017)

 What Is Discrimination?, Hartman State & Local Tax Forum (Oct 2016)

 Overturning Quill – Physical Presence Redefined, IPT Sales Tax Symposium (Sept 2016)

 Son of Quill: The Moot Court, IPT Annual Meeting (June 2016)

 Nexus Issues for Passthrough Entities, Hartman State & Local Tax Forum (Oct 2015)

 New Technologies and Associated Sales Tax Issues, COST Sales Tax (Oct 2015)

 Refund Roadblocks and How to Get Past Them, IPT Sales Tax Symposium (Sept 2015)

 Passthrough Entities, Georgetown Advanced State and Local Tax Institute (Aug 2015)

 East Coast/NJ and NY SALT Update, IPT Annual Meeting (June 2015)

 Why CEOs Should Include SALT in Their Plans, IPT Annual Meeting (June 2015)

 Passthrough Entities, IPT Advanced State Income Tax School (June 2015)

 Taxation of Foreign Affiliates, IPT Advanced State Income Tax School (June 2015)

 Passthrough Entities, COST Income Tax Conference (April 2015)

 Ethical Dilemmas in a Cost-Cutting Environment, ABA-IPT Sales/Income Tax Symposium (Mar 2015)

 New Technologies and Associated Sales Tax Issues, COST Sales Tax Conference (Feb 2015)

 Apportionment Issues, NYU Institute on State and Local Taxation (Dec 2014)

 Multistate Issues for Passthrough Entities, NJSCPA Multistate Tax Conference (Nov 2014)

 Where Passthroughs and Combined Reporting Collide, Hartman SALT Forum (Oct 2014)                      

Avoiding the Family Feud: Intercompany Transactions, IPT Sales & Use Tax Symposium (Sept 2014)        

Tax Planning, IPT Advanced State Income Tax School (June 2014)

 Refund Barriers and How to Jump Them, Telestrategies (May 2014)

 Handling State Tax Controversies, Denver TEI (May 2014)

 The Intersection of Unitary, International and Combined Reporting Issues, ABA/IPT Advanced Income Tax Seminar (April 2014)

 Sales and Use Tax Planning for Complexities of Software and Cloud Transactions, ABA/IPT Advanced Sales Tax Seminar (April 2014)

 Too Many Forks in the Road to Refunds, Council on State Taxation-Sales Tax Seminar (Feb 2014)

 Tax Disputes From Cradle to Grave, NJ IPT One-Day Session. (Oct 2013)

 State Taxation of Pass-Through Entities and Their Partners/Members, COST Annual Meeting (Oct 2013)

 Vendor Collection Responsibility, Hartman State and Local Tax Forum (Oct 2013)

 All in the Family: Don’t Be A Meathead When It Comes to Intercompany Transactions, IPT Sales Tax Symposium, (Sept 2013)

 Nationwide SALT Issues for Partnerships, NJ Society of CPAs – Monthly SALT Session (July 2013)

 Avoiding Unintended Consequences from Affiliate Transactions, IPT Annual Meeting (June 2013)

 Combination Issues from Coast to Coast, Houston TEI (May 2013)

 East v. West on Combined Reporting: The New Regime and Old Guard, Denver TEI (May 2013)

 Drill Down on Sales Factor, ABA-IPT Advanced Income Tax Seminar (March 2013)

 Sales and Use Tax Refund Roadblocks, ABA-IPT Advanced Sales Tax Seminar (March 2013)

 Use and Abuse of IRC Section 482 by States, New Jersey TEI (Feb 2013)

 Effectively Defending a SALT Audit, IPT Income Tax Symposium (Nov 2012)

 Withholding for Mobile Employees, NYU Tax Forum (Oct/Nov 2012)

 Effectively Defending a SALT Audit, IPT Income Tax Symposium (Nov 2012)

 Sales Tax in Affiliate Transactions, Hartman State & Local Tax Forum (Oct 2012)

 SALT Issues for Foreign Affiliates, IPT Annual Conference (June 2012)

 Update on SALT Controversy Issues, Orange County TEI (Mar 2012)

 Transfer Pricing Traps for the Unwary, Houston TEI (Feb 2012)

 Nationwide Developments in State & Local Tax, COST Regional (July 2011, Bala Cynwyd, PA)

 Discretionary Authority in State Corporate Income Taxes, NYU Summer Institute (July 2011, NY)           

 Grappling with Those “Other” Requirements: Business Purpose and Economic Substance, IPT Annual Conference (June 2011, San Antonio, TX)

 IPT New Jersey One-Day Tax Seminar, All-Day “MC” and Chair (June 2011, Iselin, NJ)

 Nationwide State Tax Update; Out-of-Control State Tax Agencies, TEI-Orange County (May 2011, CA)

 Business Purpose and Economic Substance, ABA/IPT Income Tax (March 2010, New Orleans, LA)

 New Jersey State Tax Update, NJ SALT Study Group (January 20, 2010, Springfield, NJ)

Cost of Performance/Market and Digital Goods, Hartman SALTForum (2010, Nashville, TN)

 Hedging and Trading for Energy Companies, START-UP SALT Round Table (2010, Richmond, VA)

Sales Taxation of Digital Goods, IPT Sales Tax Symposium (September 27, 2010, Palm Beach, CA)

 Get Your Fair Day in Court, Broadband Tax Institute (September 20, 2010, Beaver Creek, CO)

  Update on Sales and Use Tax and Regulatory Developments, IPT, NJ One-Day Tax Seminar (2010)

 Apportionment of Corporate Income Taxes, NYU Summer Institute in Taxation,(2006 - 2010, NY)     

 NY Tax Audit Issues Update – Best Practices; Institute of International Bankers Annual Conference (June 22, 2010, NY)

 Discovery: The Art of War, Georgetown Law Center's Advanced SALT Institute (2010, Washington, DC)

 State Tax Transfer Pricing Audits: Playing Darts Blindfolded, COST (2010, Phoenix, AZ)

 States Behaving Badly, COST (2010, Phoenix, AZ)

 Should Taxpayers Give Deference To Tax Agencies In Interpretation Of Tax Statutes?, ABA/IPT Sales Tax Seminar (March 2010, New Orleans, LA)

 Privilege Update, Tax Executives Institute-New Jersey, February 12, 2010, Randolph, NJ)

 State & Local Tax Best Practices, Privilege Update, Tax Executives Institute-St. Louis (2010, St. Louis, MO)

 Chair – IPT Advanced Income Tax School: Instructor - Tax Base, Supreme Court Decisions (2009, Williamsburg, VA)

 Transfer Pricing in a SALT Context, ABA/IPT Advanced Income Tax Seminar (2009, New Orleans, LA)

PwC Global Tax Symposium 2008/Americas – State Tax Issues Panel (2008, Washington, DC)

 Vice-Chair – IPT Advanced Income Tax School: Instructor - Tax Planning (2008, Atlanta, GA)

 Business Purpose & Economic Substance in State Taxation, ABA Tax Section (2008, San Francisco, CA)

The Model State Administrative Tax Tribunal Act, IPT Annual Conference (June 2008, Atlanta, GA)

  IPT New Jersey One Day Tax Seminar (April 22, 2008, Woodbridge, NJ)

  Apportionment Issues Affecting Affiliates, ABA/IPT Advanced Income Tax (2008, New Orleans, LA)

  Protecting SALT Workpapers: Textron Through SALT Colored Glasses, ABA Tax (2008, Las Vegas, NV)

  Apportionment Angst: Intangibles and Services, IPT Advanced Income Tax (2007, Sarasota, FL)

  Any Way You Slice It: Efforts to Re-Engineer UDITPA , Hartman SALTForum (2007, Nashville, TN)

  All Day Moderator – The Commerce Clause and State Taxation, Georgetown SALT Institute (2007, Washington, DC)

 Apportionment of Intangibles and Services – Is Cost of Performance Still the Way to Go? ABA Tax Section Meeting/State and Local Committee (2007, Washington, DC)

Transactions and Reorganizations; Apportionment Issues, IPT Income Tax School (2007, Cincinnati, OH)

 Challenging Issues in Implementing the Sales Factor: The Treatment of Sales from Intangibles and Services, ABA/IPT Advanced Income Tax Seminar (2007, New Orleans, LA)

 The Latest on Leasing, ABA/IPT Advanced Sales and Use Tax Seminar (2007, New Orleans, LA)

 APA, FOIA, and TBR, NYU Summer Institute in Taxation (July 2006, New York, NY)           

Gross Receipts Taxes – The Wave of the Future?, Georgetown Advanced State and Local Tax Institute (2006, Washington, DC)

 Hot Issues in Apportionment, ABA/IPT Advanced Income Tax Seminar (March 2006, Atlanta, GA)

 Applying the True Object Test, ABA/IPT Advanced Sales and Use Tax (March 2006, Atlanta, GA)

  Ohio’s New Commercial Activity Tax, TEI - NYC Chapter (October 20, 2005, New York, NY)

  Corporate Income and Franchise Taxation, NYU Summer Institute in Taxation (2005, NY)           

  Intersection of Important Multistate and International Tax Topics, TEI - NJ Chapter (2005, NJ)

  Apportionment Issues: You Know You Have Them - Section 18 & Throwback/Throwout, COST Income Tax Conference (March 2005, San Diego, CA)

  Manufacturing Exemptions, ABA/IPT Advanced Sales/Use Tax Seminar (2005, New Orleans, LA)

  Nexus Concerns for Interstate Businesses, CBIA Sales and Use Tax Conference (2005, Farmington, CT)

  Sales, Use and Transactional Tax Planning for Corporate Acquisitions & Restructurings, National Multistate Tax Symposium (February 2005, Orlando, FL)

  New York Tax Update, TEI – NY Chapter Annual Symposium (2004, New York, NY)

  New Jersey State Tax Update, NJ Society of CPAs - Mercer County Annual Meeting (2004, Trenton, NJ)

  Apportionment Pitfalls: Nationwide Developments, TEI - NJ Chapter (2004, Morristown, NJ)

  Nexus: When Does a State Have the Power to Tax, NJ Society of CPAs - Morris/Sussex County Annual Meeting (Randolph, NJ, November 2004)

 Tax Forum on Pass-Through Entities, NJSCPAs and NJ State Bar (Iselin, NJ, October 2004)

  Multistate Tax Audit Issues Update; Institute of International Bankers Annual Conference (2004, NY)

 Apportionment Apoplexy: Throwback, Throwout or Just Throw Up Your Hands, TEI - NJ Chapter (2004)

  New Jersey Tax Update, NJ State Bar Association – Tax Section (New Brunswick, NJ April 2004)

 Tax Forum on Pass-Through Entities: New Jersey Partnership Tax Developments, Joint Program by NJSCPAs, NJ State Bar Association, N.J.I.C.L.E. (New Brunswick, NJ, June 6, 2003)

 New Jersey One-Day Tax Seminar: Sales Tax Developments, IPT (Iselin, NJ, April 22, 2003)

  New Jersey Tax Changes You Need to Know, NJ State Bar Association (Orlando, FL, November 2002)

  State Tax Issues for Athletes and Entertainers, NJ Society of CPAs (Edison, NJ, October 2002)

  New Jersey Corporate Tax Changes, TEI – NYC Chapter (New York, NY, August 2002)

  Ethics in Tax Practice, Rutgers School of Law, Tax Clinic (Newark, NJ, 2001 and 2002)

  Rutgers School of Law, Annual Tax Law Career Day Panelist (Newark, NJ, 2001 and 2002)

  New Jersey 2002 Business Tax Reform Act, Essex County Bar Ass’n (Livingston, NJ, July 2002)

  Tax Issues in Electronic Commerce, Tax Executives Institute, NJ Chapter (Morristown, NJ, May 2002)

  Taxation of E-Commerce, American Conference Institute Seminar (New York, NY, April 2001)

PUBLICATIONS

Parallels between US SALT and Foreign Taxation Models, Tax Analysts, Tax Notes State and Tax Notes International, October 2, 2023

Author/Editor - New Jersey Tax Guide (American Lawyer Media, 2025, 2003 - 2020): Corporation Business Tax and Sales and Use Tax chapters

 IPT Income Tax Guide, Author - M&A and Tax Planning Chapter, Overall Editor

 The Beast of the Burden of Proof, IPT May 2012 State Tax Report

  Editorial Board, Journal of Multistate Taxation and Incentives (RIA/Warren, Gorham & Lamont)

  State and Local Tax Snafus in "No Tax" Deals, MWE Inside M&A (May/June 2010)

  The Shifting Landscape of the Work Product Doctrine, IPT Membership Newsletter, Fall 2010

  Assistant Editor, ABA Sales and Use Tax Deskbook (2010-11, 2005-06)

  Apportionment in Gross Receipts Taxes: A Brief Analysis of Constitutional Questions About Methods and Standards, BNA Tax Management Multistate Tax Report (March 23, 2007)

 The Trend Toward Alternative Taxes and How They Are (or Must Be?) Apportioned, State Tax Notes (July 3, 2006)

 Apportionment Apoplexy: Throw Back, Throw Out, or Just Throw Up Your Hands, The Tax Executive (July/August 2005)

 Ohio's New Commercial Activity Tax -- To Pay or Not to Pay? - State Tax Notes (August 22, 2005),

Comments on Multistate Tax Commission Proposed Model Statute for Addback of Certain Deductions - Multistate Tax Commission Hearing Officer's Report (published in State Tax Notes, August 1, 2005)

 Comments on Multistate Tax Commission Proposed Model Statute for Combined Reporting, State Tax Notes (April 25, 2005)

Withholding for Nonresidents: How Much Burden Should Employers Bear?, State Tax Notes (October 11, 2004)

 The Supreme Court and State Taxation: 2002-2003,A Verdict on the Continuing Viability of Equal   Protection for Business, and a Fresh Interpretation of Full Faith and Credit Deference to Other States, The State and Local Tax Lawyer, vol. 9 (ABA, 2004)

 New York’s Employment Withholding Tax Audit Initiative: Not Missing a Trick (Or a Trip), State Tax Notes (November 3, 2003)

 State Tax Considerations in Choosing a Pass-Through Entity Form of Business, Journal of Multistate Taxation and Incentives (July 2003)

Moran Towing Leaves Transactional Nexus a Sinking Ship in New York, State Tax Notes (June 9, 2003)

Sweeping Changes in Corporate Taxes, New Jersey Law Journal (July 29, 2002)

The Variance Doctrine: No Forks in the Road to Refunds, The Tax Lawyer (ABA, Winter 2002)

Sales and Use Tax Deskbook (ABA), co-author of New Jersey chapter (annual, 2000-2003)

 State Tax Notes (Tax Analysts): regular New Jersey Correspondent (2000 – 2006)

  Editor, Tax Section Newsletter, New Jersey Bar Association (2000-2002)

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