EY - Analyzing nexus and filing options issues

Ernst & Young LLP’s state income tax seminar series

Analyzing nexus and filing options issues

Seminar #1 – A historical overview of state income tax nexus

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Businesses operating in multiple states face numerous state and local tax challenges.

They must comply with each state’s unique tax system and understand how each state’s revenue department administers that state’s tax law. Questions they face include: Does the state have the right to tax the activities of a corporation in the state (i.e., is there nexus)? If so, what are the restrictions on the states’ taxing authority? Does the state require taxpayers to file state corporate income tax returns on a separate or combined basis? What’s the difference between worldwide and water’s-edge reporting?

To help address these questions and more, Ernst & Young LLP has developed a new quarterly webcast seminar series focusing on specific topics of state income taxation. The first webcast in this series will provide a historical and general overview of state income tax nexus. Topics to be discussed include:

  • US Constitutional and federal limits on states’ ability to impose income taxes on out-of-state businesses that derive income from the state
  • The substantial nexus prong of the seminal U.S. Supreme Court’s ruling in Complete Auto Transit and other key opinions of the Court
  • What the denial of review by the Court in Geoffrey, Inc. v. South Carolina Tax Commission means in the context of state taxation
  • The historical context of Public Law 86-272 and what its limits on state income taxing authority mean in today’s economy

The second webcast in this series will round out the nexus discussion, while the remaining webcasts will cover filing options and elective consolidated reporting (including distinguishing among strict separate return reporting, unitary combined reporting and elective consolidated reporting).

We hope you will be able to join our series and encourage you to ask questions during this live, interactive webcast.



Joe Huddleston

Executive Director, State and Local Tax Services, Ernst & Young LLP, Washington, DC

Joe Huddleston is an Executive Director for Ernst & Young LLP’s Indirect Tax in the National Tax office in Washington, DC having joined EY in August of 2015. Prior to joining EY, Joe served for 10 years as Executive Director of the Multistate Tax Commission. In 2011 he was named by Tax Analysts as one of the top 10 individuals who influence state tax policy and practice, and in 2012 received the 11th annual award for Outstanding Achievement in State and Local Taxation from New York University.

He also was vice president of tax solutions for Liquid Engines Inc., a tax software firm focused on advanced state income tax planning models and methodologies for multi-state and multi-national companies.

A graduate of the University of South Carolina, he received his J.D. from the Nashville School of Law and was awarded his Doctor of Laws by the University of South Carolina in 2009. Huddleston is a member of both the Tennessee and American Bar Associations and their respective tax sections.

Steve Wlodychak

Principal, State and Local Tax Services, Ernst & Young LLP, Washington, DC

Steve Wlodychak is a principal with Ernst & Young LLP’s Indirect (State and Local) Tax Practice. Based in Washington, DC, he is also the state and local tax leader of its Center for Tax Policy coordinating the firm’s point of view on emerging state and local tax legislative, judicial, and administrative issues.

He also leads the state and local transactions practice of Ernst & Young LLP. He serves both private equity and strategic investors in a variety of industries to address state and local transactional tax issues involving business combinations, reorganizations, restructurings and divestitures. He has addressed state and local tax considerations in all 50 states and on well over 800 different transactions.

Steve received a B.S.F.S. degree from Georgetown University’s School of Foreign Service, a J.D. from Seton Hall University’s School of Law and an LL.M. (Taxation) from New York University’s School of Law. He is a member of the ABA, the New York Bar Association, the District of Columbia Bar, and the New Jersey Bar.


Mark McCormick

Director of State Income Tax Services, Ernst & Young LLP, Atlanta, GA

Mark McCormick is a National Tax Partner with Ernst & Young LLP based in Atlanta. He leads the firm’s National State Income Tax and Transactions Services Group and advises clients on multi-state income and franchise tax, transaction and indirect tax matters. With over 30 years of tax advisory experience, Mark has served clients in the financial services, transportation, software/technology, utility and manufacturing industries. He has extensive experience in state tax planning and specifically the state tax implications of mergers, acquisitions, reorganizations and other significant transactions.

Mark earned his bachelor’s degree in Economics from Occidental College and his MBA from Emory University. He is a frequent speaker on state and local tax topics for COST, the Georgetown University State and Local Tax Institute, the NYU State and Local Tax Conference, the Paul J. Hartman Memorial State Tax Forum, Interstate Tax Corporation, and the Tax Executives Institute. He also serves on the advisory board for the Paul J. Hartman Memorial State Tax Forum. He is a CPA and a member of the AICPA.