Join us for some quality presentations and robust discussion with an all-star cast of SALT presenters from Reed Smith. Ask your toughest questions and get free advice from the best in the business! Network with your fellow SALT practitioners and bring your controversy questions for special guest lunch speaker Myriam Bouaziz, Executive Director of the California Office of Tax appeals.
This seminar will be followed by a 4:00pm Happy Hour at Birk's Restaurant, sponsored by Reed Smith. (Address: 3955 Freedom Circle, Santa Clara, CA 95054)
- Registration and Continental Breakfast: 8:15am - 9:00 am
- Program: 9:00 am - 3:30 pm
- Lunch: 12:00 pm - 1:00 pm
Registration and Pricing:
Advance Registration made by 5:00 pm, Wednesday, November 26, 2025:
- TEI and IPT Members: $275
- Non-Members: $375
- All registrations after 5:00 pm, Wednesday, November 26, 2025: $425
Cancellations must be received before the advance registration deadline - no refunds or credits after this time.
For questions regarding registration, contact TEI Silicon Valley at teisiliconvalley@gmail.com
MCLE/CPE Credits:
This course has been approved for up to 5.25 State Bar of California MCLE credits and up to 6.2 California Board of Accountancy CPE credits. While MCLE/CPE credit may be pre-approved in certain jurisdictions, final CPE accreditation approval is anticipated, but not guaranteed.
Agenda:
- 8:15 am - 9:00 am - Registration and Continental Breakfast
- 9:00 am - 10:00 am - What’s Going on in California? California Update and Hot Topics - Saba Shatara, Esq. and Sebastian C. Watt, Esq.
California’s tax landscape is ever-changing, with significant legislative and policy changes, significant on-going cases, and shifts in administrative priorities. This current look into California will include a discussion of recent changes in legislation, regulations, and with the California Tax Agencies. We’ll look at significant opinions, developments in sourcing, alternative and industry specific apportionment, the state’s utilization of the occasional sale rule, and the remnants multi-factor apportionment, as well as explore tips for those going through controversies--audit through appeal.
- 10:00 am - 10:10 am - Break and Networking
- 10:10 am - 11:05 am - Heartland Highlights: Midwest SALT Developments - David P. Dorner, Esq. and Richard Moore, Esq.
This Midwest focused session will provide an overview of recent statutory and regulatory changes, as well as significant developments in case law and administrative rulings. We will explore new legislation and amendments affecting taxpayers, highlight noteworthy court decisions that may influence income and sales and use tax planning and compliance, and review important guidance and publications issued by state tax authorities.
- 11:05 am - 12:00 pm - State Taxation of Foreign Income: Recent Developments & Opportunities – Sebastian C. Watt, Esq. and Saba Shatara, Esq.
Recent legislation, litigation wins, and audit activity has resulted in states including more foreign income in the tax base. For example, Minnesota now taxes 50% of GILTI, foreign dividends, and subpart F; Nebraska now taxes 100% of GILTI and subpart F; and Illinois excludes foreign cost-share reimbursements from the sales-factor denominator. These and other recent developments can be mitigated—or even create opportunities—through factor representation, worldwide combined filing, and proper characterization of what constitutes a “receipt.” This session will cover issues and opportunities related to states taxing foreign income.
- 12:00 pm - 1:00 pm - Lunch and Guest Speaker, Myriam Bouaziz, Executive Director of the California Office of Tax Appeals
- 1:00 pm - 1:55 pm - Navigating the Northeast: The Big Apple & Jersey – Aaron M. Young, Esq., CMI and Matthew L. Setzer, Esq.
This session will focus on state and local tax issues in the Northeast States with particular emphasis on New York State, New York City and New Jersey. New developments including recent audit trends, interesting state tax decisions and legislative changes will be discussed. In addition, this session will focus on corporate tax and sales tax positions and opportunities, and common audit adjustments which will be particularly helpful for those taxpayers not primarily based in the Northeast.
- 1:55 pm - 2:50 pm - Texas Roundup! (and other Southern States): Key Developments and Updates - Richard Moore, Esq. and David P. Dorner, Esq.
This session will focus on state and local tax issues in the South with particular emphasis on Texas. New developments including recent audit trends, interesting state tax decisions and legislative changes will be discussed. In addition, this session will focus on the Texas franchise (margins) tax and sales and use tax opportunities, tax exposure areas and common audit adjustments.
- 2:50 pm - 3:00 pm - Afternoon Break and Networking
- 3:00 pm - 3:30 pm - Multistate Apportionment—Reasonable Approximation for services and software and ultimate destination for sales of goods, including how to leverage data analytics - David J. Gutowski, Esq. and Matthew L. Setzer, Esq.
Market sourcing can be challenging in that it requires service providers and technology companies to consider where customers use or receive the benefit of their services. With limited information, taxpayers often resort to estimates based on relative population or GDP. In this session, we’ll use real-world use cases to show how taxpayers can use alternative datasets to more accurately apportion their receipts. We’ll also describe how manufacturers and wholesalers of consumer goods can reduce their apportionment by sourcing sales based on the ultimate consumer market—rather than where their customers happen to operate distribution centers. Finally, we’ll discuss techniques and best practices for analyzing and visualizing data, using traditional and Gen AI, and making a compelling case for alternative apportionment.
- 4:00 pm - Happy Hour @ Birk’s Restaurant (Address: 3955 Freedom Circle, Santa Clara, CA 95054)
