Contact Us
Jurisdiction to Tax, Part 1 & Part 2 : Federal Constitutional Limitations
Atlanta, Georgia, 30328
June 2nd, 2013 - June 7th, 2013
3:00 PM , Georgia, USA
Event Speaker
Mark L. Nachbar, Esq., CPA
Principal, Ryan, LLC
Principal, Ryan, Chicago, IL
– Specializes in providing multi-jurisdictional income tax and credit and incentive services.
Education/Accreditation
Juris Doctor Degree, University of Illinois, Licensed in Illinois
Bachelor of Science Degree, Management, Tulane University
Certified Public Accountant (CPA), Certified in Illinois
Principal, Ryan, LLC
Principal, Ryan, Chicago, IL
– Specializes in providing multi-jurisdictional income tax and credit and incentive services.
Education/Accreditation
Juris Doctor Degree, University of Illinois, Licensed in Illinois
Bachelor of Science Degree, Management, Tulane University
Certified Public Accountant (CPA), Certified in Illinois
Event Description
Jurisdiction to Tax, Part 1: Federal Constitutional Limitations
This session will focus on the fundamental concepts regarding the U.S. Constitution and limitations on the power of state governments to impose corporate income taxes. The speakers will discuss in detail the application of the Commerce Clause, the Due Process Clause and the Equal Protection Clause to state corporate income tax issues including relevant U.S. focus on the fundamental concepts regarding the U.S. Constitution and limitations on
the power of state governments to impose corporate income taxes. The speakers will discuss in detail the application of the Commerce Clause, the Due Process Clause and the Equal Protection Clause to state corporate income tax issues including relevant U.S.
Jurisdiction to Tax, Part II: Nexus and P.L. 86-272
This session will examine the United States Supreme Court decisions analyzing the "substantial nexus" standard of the Commerce Clause
and the “minimum contacts” standard of the Due Process Clause of the
United States Constitution and how these standards have been interpreted and developed by various state courts. The discussion will include the
development of economic nexus and attributional nexus concepts. Finally, we will examine federal statutory limitations on a state’s ability to impose a net income-based tax on out of state businesses pursuant to P.L.
86-272 and selected cases interpreting this limitation.
Learning Objectives:
► Recognize the "substantial nexus" standard of the Commerce Clause
► Recognize the “minimum contacts” standard of the Due Process Clause
► Be able to distinguish between these two standards and recognize
how they have been interpreted and developed by various state courts
► Understand the concepts of economic nexus and attributional nexus
and their application to income taxes
► Understand the federal statutory limitations on a state's ability to impose a net income-based tax on out of state businesses pursuant to P.L. 86-272 and Wisconsin Dept of Revenue v. Wm Wrigley, Jr. Co.
Case Study
Nexus and P.L. 86-272
This session will focus on the fundamental concepts regarding the U.S. Constitution and limitations on the power of state governments to impose corporate income taxes. The speakers will discuss in detail the application of the Commerce Clause, the Due Process Clause and the Equal Protection Clause to state corporate income tax issues including relevant U.S. focus on the fundamental concepts regarding the U.S. Constitution and limitations on
the power of state governments to impose corporate income taxes. The speakers will discuss in detail the application of the Commerce Clause, the Due Process Clause and the Equal Protection Clause to state corporate income tax issues including relevant U.S.
Jurisdiction to Tax, Part II: Nexus and P.L. 86-272
This session will examine the United States Supreme Court decisions analyzing the "substantial nexus" standard of the Commerce Clause
and the “minimum contacts” standard of the Due Process Clause of the
United States Constitution and how these standards have been interpreted and developed by various state courts. The discussion will include the
development of economic nexus and attributional nexus concepts. Finally, we will examine federal statutory limitations on a state’s ability to impose a net income-based tax on out of state businesses pursuant to P.L.
86-272 and selected cases interpreting this limitation.
Learning Objectives:
► Recognize the "substantial nexus" standard of the Commerce Clause
► Recognize the “minimum contacts” standard of the Due Process Clause
► Be able to distinguish between these two standards and recognize
how they have been interpreted and developed by various state courts
► Understand the concepts of economic nexus and attributional nexus
and their application to income taxes
► Understand the federal statutory limitations on a state's ability to impose a net income-based tax on out of state businesses pursuant to P.L. 86-272 and Wisconsin Dept of Revenue v. Wm Wrigley, Jr. Co.
Case Study
Nexus and P.L. 86-272