Big SALT Changes in the Louisiana Legislature

By Jay Adams, Bill Backstrom, Jeff Birdsong, Andre Burvant and Matt Mantle on Posted in Legislation, Tax News

Unless otherwise indicated, all bills noted below have been passed by the legislature and are waiting on signature or veto by the governor. Our discussion of each bill assumes the bill is or becomes law.

SB1 by Senator R. L. Bret Allain, II

TAX/FRANCHISE/CORPORATE:  Phases-out the corporate franchise tax.

SB 1 reduces the corporate franchise tax by 25% per year provided required monies are deposited into the Revenue Stabilization Trust Fund as provided in the Louisiana constitution. Combined revenues from Louisiana corporate income and franchise taxes in excess of $600 million are required to be deposited into the Revenue Stabilization Fund. If the required deposit is made into the Revenue Stabilization Fund for a fiscal year, the 25% franchise tax rate reduction will be effective for the franchise tax period that begins on the following January 1. If the franchise tax is reduced to 0%, no franchise tax will be imposed. SB 1 also addresses the continuing utilization of tax credits with respect to repealed taxes. If combined corporate income and franchise tax projections continue as they have been trending (i.e., such collections exceed $600 million for the fiscal year that will end on June 30, 2024), the first 25% reduction likely will become effective on January 1, 2025. SB 1 becomes effective only if SB 6 also is enacted into law.

In addition to the franchise tax rate reduction provided in SB 1, La. R.S. 47:601.2, which was enacted in 2021, provides for additional franchise tax rate reductions in the event certain “triggers” are met. The rate reductions provided in SB 1 and La. R.S. 47:601.2 work in tandem, such that both rate reduction provisions could apply in the same year.

SB6 by Senator R. L. Bret Allain, II

TAX/FRANCHISE/CORPORATE:  Reduces the rate of the Quality Jobs Program project facility expense rebate when certain conditions are met.

SB 6 is designed to help pay for the phase out of the franchise tax pursuant to SB 1 (discussed above) and La. R.S. 47:601.2. SB 6 reduces the sales tax and project facility rebates in the Quality Jobs program by 50% of any percentage reduction in the franchise tax rate, whether such reduction is required by SB 1 or La. R.S. 47:601.2. If the franchise tax is repealed, the rebates will be reduced by 50%. The amount of a business’s sales tax or project facility rebate for a contract or renewal is the percentage rebate in effect at the time the business files its advance notification. The reduction of the sales tax and project facility rebates due to reductions in the franchise tax rate applies only to Quality Jobs contracts with advance notifications filed after December 31, 2023. In addition, SB 6 provides that for advance notifications for incentives pursuant to the Quality Jobs program filed July 1, 2023 through December 31, 2023, related applications may be filed within 36 months of the filing of the advance notification. SB 6 becomes effective on January 1, 2024.

SB8 by Senator Jay Luneau

TAX/LOCAL:  Provides relative to interest applicable to local sales and use taxes paid under protest.

SB 8 addresses local sales and use taxes that taxpayers pay under protest in accordance with the provisions of La. R.S. 47:337.63. Under current law, to the extent the tax collector prevails in the taxpayer’s protest suit, the taxpayer must pay additional interest on the protested payment to the collector at the rate applicable to tax deficiencies, not to exceed 12%. SB 8 would eliminate the onerous requirement that the taxpayer making the payment under protest must pay additional interest if the tax collector prevails. SB 8 further provides that, to the extent the taxpayer prevails in the protest suit, the tax collector must refund that tax to the taxpayer with interest at the judicial interest rate published in the state register.

SB89 by Senator Jeremy Stine

TAX/INCOME/PERSONAL:  Provides relative to the net capital gains deduction for individual income tax.

SB 89 provides an exclusion from individual income tax for capital gains generated by the sale of certain Louisiana businesses, provided a number of criteria are satisfied. As originally filed, this legislation would have reduced the documentation necessary to claim the exclusion on an individual income tax return. However, SB 89 was amended to give the Louisiana Department of Revenue the authority to issue binding regulations for the ostensible purpose of reducing administrative requirements, while simultaneously authorizing the issuance of other regulations limiting eligibility for the exclusion. Stay alert for proposed regulations on this topic!

HB428 by Representative Thomas Pressly

TAX/INCOME TAX:  Extends to estates, trusts, and partnerships the flow-through entity income exclusion allowed to individuals.

In response to the 2017 federal Tax Cuts and Jobs Act, Louisiana implemented work-around legislation for the $10,000 federal income tax deduction limit for state and local taxes paid by individuals: the pass-through entity (PTE) election. HB 428 makes two technical modifications to the PTE election. First, PTEs which have made the election are now permitted to unilaterally revoke it for subsequent tax years; however, once revoked, a PTE will not be eligible to make the election again for five years. Second, HB 428 clarifies the tax treatment for partnerships, S-Corporations, and trusts that own interests in PTEs which make the election. Notably, the legislation does not address the tax treatment for grantors of grantor trusts that own interests in PTEs which make the election.

SB5 by Senator R. L. Bret Allain, II

TAX/AD VALOREM:  Provides for alternatives in lieu of payment under protest for challenges to ad valorem tax assessments.

SB 5 removes the requirement that a taxpayer challenging the correctness of a property tax assessment pay the taxes under protest while the taxpayer’s appeal is pending before the Louisiana Tax Commission, or during any appeal if the appeal is brought by any party other than the taxpayer; i.e. the assessor. If the taxpayer appeals the Commission’s decision, the amount paid under protest, or of alternative security, shall be based on the Commission’s decision, and not the original assessment. Importantly, SB No. 5 allows a taxpayer to post security instead of paying the entire amount of the disputed taxes under protest. In addition to a bond, the statute provides for “other security” including, but not limited to, a pledge, collateral, lien, mortgage, factoring of accounts receivable, or other encumbrance of assets. To post security (as opposed to paying under protest), the taxpayer must file a rule to set security with the Board of Tax Appeals or district court within the deadline to file an appeal. With the petition, the taxpayer must provide evidence of its ability to post a bond or other security. The collector has the ability to conduct discovery about the value and validity of the proposed security. The Board or district court can decide the amount of security required to be posted. A taxpayer challenging the legality (versus the correctness) of an assessment can also use this procedure. Any undisputed amounts that are not subject to appeal must be paid to the collector.

HB256 by Representative Gregory A. Miller

TAX/SALES & USE:  Requires extension of the deadline to pay local sales taxes when the deadline for payment of the tax falls on certain holidays.

HB 256 (Act 21) officially extends the deadline to pay local sales/use taxes to the next business day when the deadline falls on a state or federal holiday on which banks are closed, and prohibits the accrual or interest or penalties during the extension.

HB558 by Representative Beau Beaullieu

REVENUE DEPARTMENT:  Provides for the collection and remittance of state and local sales and use taxes.

HB 558, in pertinent part, transfers the responsibility for the management, maintenance, and supervision of a single, uniform electronic local return and remittance system for sales tax remittances in La. RS 47:337.23 from the Louisiana Department of Revenue to the Uniform Local Sales Tax Board (ULSTB). As part of this new legislation, the legislature imposed additional duties on the ULSTB with regard to this system, whereby the ULSTB has a duty to manage, maintain, and supervise this system, by which taxpayers can remit “state and local” sales and use taxes through a single transaction in the system. The ULSTB has also been tasked via this new legislation to design, implement, manage, maintain, and supervise this single remittance system. The system was previously legislatively provided to the Department of Revenue; however, no funding had previously been provided. The new legislation provides a direct funding mechanism for the system. Specifically, collectors can enter into contracts directly with the ULSTB. However, under the new legislation, if a particular collector/taxing jurisdiction does not enter into a contract directly with the ULSTB, the ULSTB is now required to impose a fee based on the individual parish’s share of the states’ total population, according to the most recent federal decennial census. Funding will also be provided based on a portion of collections from the local sales and use tax imposed on motor vehicle transactions. This legislation is to be effective as of January 1, 2024. The new uniform electronic local return and remittance system is also required to be fully designed, implemented, and available for use by taxpayers no later than January 1, 2026. The goal of this new legislation is to provide a centralized filing and remittance hub for Louisiana sales taxes. The new legislation, however, does not address enforcement, audits, and other mechanisms/responsibilities of local collectors.

HB171   by Representative Beau Beaullieu

TAX/SALES & USE:  Provides relative to requirements for dealers and marketplace facilitators to collect and remit sales and use taxes.

Following trends in other states, HB 171 (now Act 15) modifies Louisiana’s factor presence economic nexus thresholds under relating to “dealers” and marketplace facilitators by removing the “number of transactions” factor threshold and retaining only the dollar amount threshold. Additionally, HB 171 amends the factor presence economic nexus thresholds for marketplace facilitators such that only “retail sales” by such marketplaces will be counted for purposes of the $100,000 threshold. The legislation also provides that applications for registration of marketplace facilitators will be accepted or denied within 30 days of submission, and if accepted, the facilitator’s tax collection obligation will begin within 60 days of the triggering event leading to economic nexus being met.

If you have any questions about the bills noted in this post, please reach out to a member of our Jones Walker LLP State & Local Tax team.

Flashback Friday to the COST Southeast Regional State Tax Seminar in Memphis, TN

By cfarley and Jones Walker LLP on Posted in Presentations

Partners on the state and local tax team delivered several presentations at the Council on State Taxation (COST) Southeast Regional State Tax Seminar hosted by Pfizer on May 16, 2023, in Memphis Tennessee. Partners Jay Adams, Andre Burvant, John Fletcher, and Jeff Birdsong presented “Discussion of State Tax Cases, Issues & Policy Matters to Watch,” moderated by COST president and executive director Doug Lindholm. Andre, John, and Jeff also presented “Internal Reorganizations: Looking Beyond Due Diligence, Deal Documents, and Closing. What Else Does the SALT Professional Need to Consider?” The seminar covered significant state tax issues developing in Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, South Carolina, and Tennessee.

Join us for our State & Local Tax Financial Services Roundtable and Networking Reception

By Jones Walker LLP on Posted in Jones Walker Announcements, Presentations

When:

Thursday, June 22, 2023
Program: 2:00 p.m.–4:00 p.m. | Networking Reception: 4:00 p.m.–6:00 p.m.

Location:

Ace Hotel
20 W 29th St | New York, NY 10001

Summary:

This session will cover issues of concern to the financial services industry, including sourcing of receipts from trading and investment income, the treatment of “other financial instruments” and tangible personal property for purposes of New York sourcing, legislative developments, and audit issues. Indirect tax issues will also be addressed, including analysis of New York sales tax developments, the use of the true object test, and digital ad tax developments around the country.

Registration is complimentary.

Speakers:

Questions or to Register:

Courtney Farley | cfarley@joneswalker.com

Program not open to tax collectors.

New York ALJ Narrows the Definition of “Sale” for Apportionment Purposes

By Alysse McLoughlin and Katie Quinn on Posted in Jones Walker Announcements, Legislation, Tax News

In Matter of Sunoco Inc. (R&M) Combined Affiliates, a Division of Tax Appeals Administrative Law Judge (ALJ) determined that Sunoco’s sale of oil pursuant to buy/sell arrangements was not a “sale” for purposes of computing Sunoco’s New York State Article 9-A sales factor.   The ALJ’s determination was based upon her finding that Sunoco was exchanging the oil with the counterparty and that such exchange was not a “sale” for purposes of determining the New York State sales factor.

Background

Sunoco’s buy/sell arrangements were with other oil providers and allowed Sunoco to more efficiently fill orders from its customers.  If a customer wanted a certain type of oil at a certain geographical location and Sunoco did not have the inventory in that given location, Sunoco would, pursuant to the buy/sell contract, sell oil to its counterparty and purchase oil from its counterparty at the desired location for resale to its customer.  The buy/sell transactions often occurred concurrently, such that Sunoco would buy oil and sell oil to the counterparty simultaneously.  Nevertheless, the facts show that the sale of oil and the purchase of oil were two separate transactions.

Presumably to avoid the constant transfer and retransfer of cash between the parties to the buy/sell contract, some of petitioner’s buy/sell contracts were “net-out” agreements. Pursuant to a net-out agreement, the payment provisions of a buy/sell contract were amended so that only the net payable was transferred between the parties on a monthly basis. 

When Sunoco was on the sale side, the record demonstrates that “it transferred legal title to, possession of, and risk of loss for the Oil to the purchasing petroleum dealer….”  The parties invoiced each other for the oil, which was priced at fair market value.  Sunoco “recorded the gross invoice amount from the sale side in both its revenue and receivable accounts” and “did not offset the sale receipts with the purchase expense to record only a net entry for the sale.” 

For financial reporting and federal income tax purposes, however, Sunoco classified all amounts from the buy/sell contracts as costs of goods sold (the receipts from the sell side were used to offset costs of goods sold).   

Determination

The ALJ determined that Sunoco’s sale of oil under the buy/sell agreements was not a “sale” of tangible personal property for purposes of computing the New York State receipts factor.  In reaching that determination, the ALJ said:

The buy/sell agreements that petitioner participated in were exchanges of inventory and not receipts from the sales of tangible personal property. The word “sale” is not defined in Tax Law former § 210 (3) (a) (2) (A). Accordingly, it must be construed “according to its ordinary and accepted meaning at the time [of enactment]” (Matter of Catalyst Repository Sys., Inc., Tax Appeals Tribunal, July 24, 2019) (internal quotations omitted) quoting Gevorkyan v Judelson, 29 NY3d 452, 459 [2017]. Black’s Law Dictionary defines a sale as “[t]he transfer of property or title for a price” (see Sale, Black’s Law Dictionary 1337 [8th ed. 2004]).

Here, inventory was transferred, and other inventory was provided in return. According to petitioner’s response to the Division’s IDR number 6, there were occasions where the parties to a buy/sell agreement would also exchange the full monetary value of the Oil instead of the net difference between what was bought and what was sold. However, that does not change the substance of the transaction. The transaction at issue was not a sale for purposes of Tax Law former § 210 (3) (a) (2) (B). Oil would not have been provided in a buy/sell transaction if Oil was not also being acquired in return. Accordingly, petitioner’s sale side of the buy/sale transactions were not sales of tangible personal property constituting business receipts.

The ALJ essentially holds that a sale is not a “sale” for sales factor purposes unless cash is actually received in return for the property.  Sunoco sold the oil for a monetary price under the buy/sell arrangements, but collected only the net amount owed under the buy/sell on a monthly basis pursuant to the payment terms.  Nevertheless, the ALJ determined that there was no “sale.” 

This determination could have widespread, and probably unintended, results.  Imagine a person wants to return a sweater ($50 sales price) at a retail store and while at the store finds a pair of pants ($50 sales price) that she likes and wants to purchase.  Instead of returning the sweater, taking the $50, then purchasing the pants and passing that $50 back to the cashier, the person exchanges the sweater for the pants.  Under the rationale in Sunoco, the sale of the pants is not a “sale” by the retailer.   This is an extreme example, but there are many instances where counterparties to a transaction net payments to avoid the unnecessary trading of cash.

Sunoco’s motive for entering into the buy/sell arrangement was also considered in determining whether there was a “sale.”  But why one enters into a transaction should have no bearing on whether there is a sale.  Sunoco entered into the buy/sell contracts in order to acquire oil that it could more efficiently sell to its customers; that should not mean oil sold under the arrangements was not “sold.” 

The ALJ also focused on the fact that the receipts from the buy/sell contracts were reported on Sunoco’s federal returns as offsets to its cost of goods sold instead of on Line 1 as “receipts.”  But, as the taxpayer pointed out, whether the amount received on the sell side of the buy/sell contracts reduced the costs of goods sold deduction or increased its receipts had no impact on Sunoco’s federal taxable income. 

In addition to the it should be noted that this case may not be consistent with the 2022 decision of the Appellate Division in BTG Pactual NY Corp. v. N.Y. State Tax Appeals Tribunal, 165 NYS3d 149 (App. Div. 3rd Dept., 2022).  In that case, the Appellate Division determined that the doctrine of federal conformity did not necessarily apply for New York apportionment issues because there is no apportionment at the federal level.   

Conclusion

While ALJ determinations are not precedential, practically speaking, this case could significantly impact the definition of “sale” for purposes of computing the Article 9-A receipts factor.  Please reach out to Alysse McLoughlin or Katie Quinn on the Jones Walker SALT team with any questions.  

New Automatic Filing Extensions for Certain Louisiana Taxpayers

By Jeff Birdsong on Posted in Legislation, Tax Procedure

In the 2022 Louisiana Regular Legislative Session, the Louisiana Legislature enacted Act 410, modifying the deadlines for filing partnership, fiduciary, and corporate income tax returns. Specifically the Act obsoleted the process by which most taxpayers obtained extensions of time to file. These changes were then implemented by the Louisiana Department of Revenue (the Department) in final regulations promulgated in April 2023 and clarified in Revenue Information Bulletin 23-011 issued on May 5, 2023.

Prior to the enactment of Act 410, the Department had discretion to approve corporate income tax return filing extensions up to the later of (a) the extended due date of the taxpayer’s federal income tax return for the same period or (b) seven months from the original filing deadline. Though regularly approved, taxpayers had to request the extensions, and the Department retained discretion over their approval.

New Automatic Extension for Corporate Income Taxpayers

Starting with the 2022 tax year, corporate taxpayers that timely request a federal extension to file their income tax return will receive an automatic extension to file their Louisiana Corporation Income and Franchise Tax (CIFT) return for the same period to the later of (a) the date of the federal extension or (b) six months from the original filing deadline, all pursuant to La. R.S. 47:287.614 as amended by Act 410.  For 2022 calendar year filers, the original filing deadline is May 15, 2023, yielding an extended due date of November 15, 2023 under both methods.

Eligible taxpayers do not need to file a paper or electronic extension request form; however, they must check the box on their ultimately-filed CIFT return indicating they timely requested the federal extension.[1]

Note that the automatic extension to file is not an extension of time to pay Louisiana taxes; La. R.I.B. 23-011 details the methods by which corporate taxpayers can make an extension payment. Further, if a taxpayer qualifies for the automatic extended filing period, but fails to file their CIFT return by the extended date, late filing penalties will be assessed starting from the original due date.

CIFT taxpayers will still be permitted to request a discretionary extension from the Department to file their CIFT returns on an extended basis, but the maximum period of time for such a discretionary extension has been shortened from seven to six months from the original filing deadline. Taxpayers in this situation, e.g. those that did not request a federal extension but desire a Louisiana extension, should follow the process set out in LAC 61:III.2503(A)(3) to request a discretionary extension.

A Note for Entities Which Solely File Corporation Franchise Tax Returns

Taxpayers which file a Louisiana Corporation Franchise Tax return, but not a Louisiana Corporation Income Tax return are ineligible for the automatic extension. [2] Instead, these taxpayers must request a discretionary extension as set forth above. Our understanding is that the Department will be sympathetic to these requests given the taxpayers’ statutory ineligibility for an automatic extension. Again, any such extension would be limited to the later of (a) the date of the federal extension or (b) six months from the original filing deadline.

New Automatic Extension for Partnership and Fiduciary Returns

Similar to corporate taxpayers, starting with taxable periods beginning on or after January 1, 2022, Act 410 created an automatic six-month extension for filing Louisiana partnership and fiduciary income tax returns; however, unlike with corporate taxpayers – partnerships and fiduciary filers do not have to request a federal extension in order to be eligible for the Louisiana extension.[3] Rather, they just need to remit the amount of taxes owed by the original due date and file their Louisiana income tax returns by the extended due date. Failure to do either will result in penalties (and in the case of failure to remit taxes due, interest).

If you have any questions, please contact Jeff Birdsong, Bill Backstrom, or another member of our Jones Walker LLP SALT team.

[1] LAC 61:III.2503(B).

[2] LAC 61:III.2503(B)(1).

[3] La. R.S. 47:103(D)(2); LAC 61:III.2505(B) and LAC 61:III.2507(B).

Register now for COST‘s Southeast Regional State Tax Seminar in Memphis

By Jones Walker LLP on Posted in Presentations

Jones Walker SALT team members Jay Adams, Andre Burvant, John Fletcher, and Jeff Birdsong will discuss state tax cases, issues, and policy matters to watch. Additionally, the team will cover internal reorganization and looking beyond due diligence, deal documents, and closing.

Council on State Taxation (COST) Southeast Regional State Tax Seminar

Date: Tuesday, May 16, 2023

Location: Pfizer Inc. | 949 S Shady Grove, 5th Floor | Memphis, TN 38120

Click here to register.

Budget Bill would Shake Up Tax Litigation in New York

By Alysse McLoughlin and Katie Quinn on Posted in Legislation, Tax News

The New York Budget Bill, SB.4009/A.B.3009, introduced on Sunday includes a provision allowing the NYS Department of Taxation and Finance (“Department”) to appeal determinations of the Tax Appeals Tribunal to the New York State Appellate Division under certain circumstances. Currently, the Tax Law allows only the taxpayer to appeal determinations of the Tax Appeals Tribunal.

Specifically, the bill would give the Department the right to appeal…

“a decision of the tax appeals tribunal that is premised on interpretation of the state or federal constitution, international law, federal law, the law of other states, or other legal matters that are beyond the purview of the state legislature.” 

This is broad. The Department would have the right to appeal a determination on any issue other than one involving the construction or interpretation of only New York State law.  Many complex tax issues include a constitutional or federal law component and decisions on these issues would be appealable by the Department. 

What if the provision is enacted?

We expect that the provision will be enacted as it was included in Governor Hochul’s executive budget proposal.  If this provision is enacted it will dramatically change the appellate landscape for tax cases in New York. Currently, New York taxpayers can defeat an assessment or secure a refund through a favorable conclusion in the Division of Tax Appeals. (The Division of Tax Appeals process is composed of two steps. First, the matter is tried before an Administrative Law Judge, with the Administrative Law Judge level being akin to a trial court where the record is set. Second, either party can appeal an Administrative Law Judge determination to the Tax Appeals Tribunal. If the Department wins at the Tax Appeals Tribunal, the taxpayer can appeal the determination to the Appellate Division of the New York courts. However, if the taxpayer wins at the Tax Appeals Tribunal level, the Department cannot appeal; the Tribunal’s determination for the taxpayer is final.) If the new provision is enacted, determinations of the Tax Appeals Tribunal in favor of the taxpayer will no longer be final in all situations, and taxpayers will face the prospect of having to litigate a favorable decision within the New York courts. This would give the Department at least three, and potentially four, bites at the apple! This could – and likely will – add years and significant litigation costs to the protest process.  

Other Considerations

Pursuant to the budget bill, if the Department appeals a Tax Appeals Tribunal Determination any interest and penalties that would otherwise accrue on the underlying liability would be stayed until 15 days after a final determination (i.e., the issuance of a judicial decision where no further appeals are allowed).   Even so, the Department should consider adopting a formal “payment under protest” program, allowing taxpayers appealing assessments to pay the tax to stop interest from accruing during the Division of Tax Appeals dispute without forfeiting any protest rights and converting their assessment into a refund claim.  The Department has entered into such agreements informally, but a formal program would streamline the process.

From a litigation strategy standpoint, the provision may impact future decisions of the New York State Appellate Division, which has historically heard only cases that the Department has won before the Tax Appeals Tribunal. A determination of the Tax Appeals Tribunal can only be overturned by the court in certain circumstances, such as if the determination was arbitrary and capricious. This high standard for appeal has been detrimental to taxpayers. However, if this provision is enacted, the deference to the Tax Appeals Tribunal should apply to taxpayers in defending cases where the Department is the appellant.  However, the additional time and cost that this provision adds to the litigation process is a huge price to pay for any speculative benefit for taxpayers in Appellate Division appeals. 

If this provision is enacted, it will certainly shake up appellate procedure in New York.  Please reach out to Alysse McLoughlin or Katie Quinn on the Jones Walker SALT team with any questions.  

Jones Walker Strengthens State and Local Tax Practice in Northeast – Adds Attorneys in DC and New York

By Jones Walker LLP on Posted in Jones Walker Announcements

Jones Walker LLP announced today that the firm has welcomed two new partners to its growing state and local tax (SALT) team, Chris Lutz and Kathleen Quinn.

Chris joins the Washington, DC office, and Katie joins the New York office. With the addition of former Barclays Capital partner and IRS veteran Alysse McLoughlin in 2021, these additions represent a strategic and continued expansion of the firm’s SALT presence in the Northeast.

“We are pleased to welcome Chris and Katie to our growing state and local tax team. These additions and their combined practices allow us to expand our capabilities and also our geographic reach on a multistate basis, with a stronger presence in Illinois, New Jersey, and New York,” said Bill Hines, managing partner of Jones Walker. 

The Jones Walker SALT team has some of the most experienced tax attorneys in the nation who guide clients through diverse state and local tax systems in many parts of the country. The SALT team attorneys are particularly poised to handle matters involving the oil and gas exploration and production, oilfield services, refining, mining, manufacturing, transportation, telecommunications, broadcasting, paper, and healthcare industries. The popular Cooking With SALT blog provides timely insights on recent legal and practical developments on matters involving income, franchise, net worth, gross receipts, sales/use, business and occupational license, severance, ad valorem property, and other miscellaneous taxes.

About Chris Lutz

Chris is a highly experienced state and local tax professional who provides sophisticated counsel to regional, national, and international businesses on the full spectrum of state and local income, sales and use, and related taxes. He works with companies across the country to develop effective tax strategies and resolve disputes heard before state courts and administrative tribunals. Chris’ clients include publicly traded Fortune 500 corporations as well as midsize, privately held businesses; emerging growth companies; and startups with interests, investments, and operations in numerous industries, including financial services, insurance, technology, telecommunications, biopharmaceuticals, retail, automotive, and energy.

About Katie Quinn
Katie advises multinational, national, and regional businesses, as well as high-net-worth individuals, on the full spectrum of state and local tax matters, including income taxes and sales and use taxes. She has represented clients at every stage of state and local tax controversies, including audits, administrative hearings, trials, and administrative and judicial appeals. Katie’s clients have interests, investments, and operations across a wide range of industries, including financial services, private equity, technology, retail, and media and entertainment. She also helps companies and industry organizations work with legislators and regulators across the country to develop effective, business-oriented tax laws and policy.

About Jones Walker

Jones Walker LLP (joneswalker.com) is among the largest 135 law firms in the United States. With offices in Alabama, Arizona, the District of Columbia, Florida, Georgia, Louisiana, Mississippi, New York, and Texas, we serve local, regional, national, and international business interests. The firm is committed to providing a comprehensive range of legal services to major multinational public and private corporations, Fortune 500 companies, money center banks, worldwide insurers, and emerging companies doing business in the United States and abroad.

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