COST’s 2022 Sales Tax Conference & Audit Session

Pillsbury SALT partner Carley Roberts will present at COST’s 2022 Sales Tax Conference & Audit Session on March 10.


Carley is partnering with Mark Loyd (Dentons) to present on the topic, “Defending Against States’ Use of Deference, Substance Over Form, & Sham Transaction Doctrines.” State Tax Administrators have pushed the use of deference to gain an advantage and the state courts are increasingly allowing the use of federal income tax doctrines like substance over form and sham transaction in making transactional tax assessments. Historically, the rule in sales tax has been “form over substance;” however, recently state tax administrators are more aggressively applying a “substance over form” standard (and similar doctrines) as the basis for transactional tax assessments. The presenters in this session will detail how taxpayers can fight back against these aggressive tactics.

COST’s Sales Tax & Audit Session is a two-and-a-half-day conference featuring presentations on the most recent transactional tax developments, initiatives, and case law topics. For more information and to register, please see the event page.

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