Instructor(s) Fahrenbach, Robert
The course will focus primarily on multistate income and sales/use tax issues. Time permitting other tax regimes such as gross receipts and transfer taxes will also be addressed. Wisconsin statutes and laws will be used as a model for discussion and to draw contrasts/ comparisons with approaches taken by other states. The course will emphasize both operational and transactional issues as well as US Constitutional ramifications of various state tax regimes. There will be special emphasis on current issues of significance and practical issues faced by in-house and external counsel. Lectures will touch on financial reporting concerns and risk mitigation strategies. At the end of the course the student will be in a position to critically analyze statutory and regulatory rules, apply pertinent Constitutional guidance and identify issues of concern to formulate potential resolutions. The student should have completed Tax 1.
By the end of this course, students should:
• Understand the major state/local taxing regimes and the critical issues.
• Gain an appreciation for the interaction of state taxing rules with US federal and foreign country taxing regimes.
• Develop an awareness of how state taxation can affect business transaction, organization and restructuring.
• Have acquired knowledge of the basic legal doctrines of U.S. constitutional law affecting the authority of state/local jurisdictions to subject individuals and businesses to taxation or to tax collection responsibilities.
• Gain insight on practical issues facing taxpayers and their advisors in dealing with multiple taxing authorities both from a risk assessment and planning perspective with a focus on the challenges of advising clients in an uncertain and constantly shifting tax climate.