all that’s new in illinois 12 th annual taxpayers’ federation of illinois state and local tax...

ALL THAT’S NEW IN ILLINOIS

12th Annual Taxpayers’ Federation of Illinois State and Local Tax Conference

September 20, 2011

Fred O. MarcusHorwood Marcus & Berk, Chtd.(312) [email protected]

Michael A. LovettPricewaterhouseCoopers LLP(312) [email protected]

Agenda

• Legislation• Enacted• Proposed

• Judicial• Income / Franchise• Other

• Regulations• Adopted• Projects on the Agenda

• Current Developments

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Enacted Legislation (96th General Assembly)

S.B. 3655 Research and Development Credit

(P.A. 96-0937)(Signed 6/23/2010)• Provides that the research and development credit applies

for taxable years ending on or after December 31, 2004 and ending prior to January 1, 2011

• Credit was to sunset on December 31, 2009 under Act’s automatic sunset provisions

• Research and development credit may not be carried forward to any taxable year ending on or after January 1, 2011

3


S.B. 1578 Small Business Jobs Creation Tax Credit

(P.A. 96-0888)(Signed 4/13/2010)• Provides tax credit to small business by Department of

Commerce and Economic Opportunity (DCEO)• Applies to taxpayers with fewer than 50 employees that

have hired a new employee during the State’s fiscal year 2011

• Credit not to exceed $2,500 ($50,000,000 total)• Dept. Press Release “Illinois Small Business Jobs Creation

Tax Credit/Certificates from DCEO” (June 29, 2011)• Reminder that the credit is only available to businesses and non-

profits that registered with the DCEO on or before June 20, 2011• Clarifies when and how the credit is to be claimed

4


S.B. 3089 EDGE Tax Credits Expansion

(P.A. 96-0905)(Signed 6/4/2010)• Expands the provision allowing certain motor vehicle

manufacturer to elect to claim the EDGE credit against their withholding tax obligations to apply to heavy duty truck manufacturer that meet certain criteria

• Intended to allow certain taxpayer to take advantage of the provisions of P.A. 96-834, which passed during veto session

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S.B. 2505 (P.A. 96-1496)(Signed 1/13/2011)• Corporate income tax rate increased from 4.8% to 7% beginning on

January 1, 2011• On January 1, 2015, the rate decreases to 5.25%• Reduced again to 4.8% on January 1, 2025• Note that Illinois also imposes a 2.5% replacement tax on

corporations

• Special rules apply to fiscal-year taxpayers• Taxpayers with tax years that overlap date on which a rate change

occurs can use a weighted average of the two rates or can elect to specifically account for income and expenses earned during each part of the tax year

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S.B. 2505 (P.A. 96-1496)(Signed 1/13/2011)• For all corporations (excluding S corporations), NOL

carryovers are suspended for tax years ending after December 31, 2010 and prior to December 31, 2014

• No taxable year for which a deduction is suspended will be counted

• Fiscal year taxpayers have a four-year suspension• The rule suspending carryovers does not contain an

exception for corporations whose final taxable year falls within the period of suspension. IT 11-0013-GIL (July 8, 2011)

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Income Tax• SB 4 – Amends EDGE Act (P.A. 97-0002)(Signed

5/6/2011)• Provides election to claim EDGE Credit against

withholding tax obligations for certain narrowly defined industries

• Contains recapture provisions for not meeting investment or job creation and retention requirements

• Provides that taxpayers may not take credits awarded pursuant to Film Production Services Tax Credit Act for tax years beginning on or after 5 years after effective date of SB 4

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Income Tax• SB 398 (P.A. 97-0003)(Signed 5/6/2011) – Film

Production Services Tax Credit Act• Amends Film Production Services Tax Credit Act of

2008 • Provides that taxpayers not entitled to take credit for

tax years beginning on or after 10 years (instead of 5 years) after the effective date of SB 4

• Provides that General Assembly may extend sunset date by 5 year intervals

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Income Tax• SB 2168 (P.A. 97-0203)(Signed 7/28/2011)

• River Edge Historic Rehabilitation Tax Credit• Creates credit equal to 25% of qualified expenditures

incurred by eligible taxpayer for restoration and preservation of qualified historic structure located in River Edge Redevelopment Zone

• The qualifying expenditure must equal at least $5,000 or more and must exceed 50% of the purchase price of the property

• Applicable to tax years beginning on or after January 1, 2012 and ending prior to January 1, 2017

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Income Tax• HB 2955 (P.A. 97-0507)(Signed 8/23/2011)

• Technical Corrections Bill • Broad technical correction bill that amends the Income Tax Act

to achieve consistency with the IRS Code and clarifies the State’s approach to taxation linked to insurance premiums, net losses, life insurance income, and income from a real estate mortgage investment conduit

• Various administrative and technical changes• Provides that deduction for partnership personal service income

and income distributable to entities subject to Replacement Tax are not subject to sunset provisions

• Many of the provisions have different effective dates

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Income TaxHB 2955 (P.A. 97-0507)(Signed 8/23/2011)• Technical Corrections Bill

• Broadly permits full and partial combination of holding companies by amending IITA Section 1501(a)(27)’s exception to allow combination of a “holding company that would otherwise be a member of a unitary business group with taxpayers that apportion business income under any of subsections (b), (c), or (d) of Section 304”

• Defines what a holding company is and how the income and apportionment factors should be allocated to the unitary groups

• The holding company provisions are intended to clarify existing law

12


Sales/Use Tax• HB 3659 (P.A. 96-1544)(Signed 3/10/2011)

• Amends Illinois use tax and service use tax laws, beginning 7/1/2011, by adopting click-through nexus provisions applicable to certain retailers

• $10,000 threshold of total sales from in-state relationships during the preceding 4 quarterly periods

• Unlike in other states adopting similar “click-through” nexus provisions, there is no “presumption” that nexus exists that can be rebutted by the out-of-state retailers

• Also adopts expanded affiliate nexus provisions for certain retailers that use the same marks/trade names as in-state businesses

13


Sales/ Use Tax• SB 0145 (P.A. 97-0038)(Signed 6/28/2011)• Nursing Home Care Act; Exemptions for certain food and medicine

• Provides that the exemption applicable to goods purchased for use by a person receiving medical assistance under Art. 5 of the Public Aid Code also applies to a person who resides in a licensed facility as defined in the Specialized Mental Health Rehabilitation Act (SMHRA)

• Provides a reduced 1% service occupation tax and service use tax rate applies to food prepared for immediate consumption and transferred incident to a sale of service by an entity licensed under the SMHRA

14


Sales/ Use Tax• SB 401 (P.A. 97-0073)(Signed 6/30/2011)• Use Tax-Centralized Purchasing (Temporary Storage Exemption)

• Extends exemption to June 30, 2016 for use of tangible personal property purchased from an Illinois retailer by a taxpayer engaged in centralized purchasing activities in Illinois who will, upon receipt of the property in the state, temporarily store the property in Illinois (i) for the purpose of subsequently transporting it outside the state for use or consumption solely outside Illinois or (ii) for purpose of being processed, fabricated, or manufactured into, attached to, or incorporated into other tangible personal property to be transported outside Illinois and used or consumed solely outside Illinois

15


Property Tax• HB 212 (P.A. 97-0577)(Signed 8/26/2011)

• Business Corridor Abatement• HB 1218(P.A. 97-0577)(Signed 8/25/2011)

• Tax Purchaser/Sale Transparency• HB 1926 (P.A. 97-0451)(Signed 8/19/2011)

• Housing Authority Exemption• HB 234(P.A. 97-0296)(Signed 8/11/2011)

• Open Space Valuation Changes• SB 1804 (P.A. 97-0533)(Signed 8/23/2011)

• Special Service Area Property Tax Covenants

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Property Tax• SB 1386 (P.A. 97-0521)(Signed 8/23/2011)

• Property Tax Overpayments• HB 1518(P.A. 97-0481(Signed 8/22/2011)

• Senior Citizen Real Estate Tax Deferral/High Speed Rail Property Valuation

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Unclaimed Property• HB 1560 (P.A. 97-0270)(Signed 8/8/2011)

• Unclaimed Wages - Limitation• Amends 765 ILCS 1025/2 and 2a• Provides that unclaimed wages, payroll and salary held or

owing by a banking or financial institution will be presumed abandoned if outstanding for more than one year from the date of issuance

• Additionally, business associations shall report unclaimed wages, payroll and salary, in any form, after remaining unclaimed for more than one year

• Effective August 8, 2011

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Miscellaneous Taxes• SB 43 (P.A. 97-0353)(Signed 8/12/2011)

• Taxation Disclosure Act• Provides that the Department of Revenue shall make tax rate

information available on its website, including:

Municipal rate information for use and occupation tax;

Corporate income tax rates; and

State and local excise tax rates• Provides that the information required to be provided must be

made available in a viewable and downloadable format, and must be updated regularly

• Effective July 1, 2012

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Miscellaneous Taxes• SB 2063 (P.A. 97-0463)(Signed 8/19/2011)

• Prepaid Wireless Surcharge• Creates a prepaid wireless 911 surcharge of 1.5% on retail

transactions of “prepaid wireless telecommunications services”• “Prepaid wireless telecommunications service” means a wireless

telecommunications service that allows a caller to dial 9-1-1 to access the 911 system, when the service is paid for in advance and is sold in predetermined units which decline with use in a known amount

• Home rule municipalities having a population in excess of 500,000 may impose a prepaid wireless 911 surcharge not to exceed 7% per retail transaction sourced to that jurisdiction.

• Effective January 1, 2012

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Proposed 2011 Business Tax Law Changes

Income Tax• SB 1741 Income Tax-Estimated Taxes (referred to

Assignments 7/23/2011)• Provides if taxpayer is entitled to refund after payment

of fourth installment, may apply amount of refund to first installment due in next taxable year

• SB 1900 Brownfield Credit (Re-referred to Rules Committee 5/31/2011)• Provides credit against income tax for eligible projects

related to remodeling, rehabilitation, modernization, or remediation of contaminated property in Illinois

21


Income Tax• HB 1084 Business Mandate Note (Referred to

Assignments 7/23/2011)• Provides that every bill that directly increases cost of

doing business in State shall have brief explanatory statement or note with reliable estimate of anticipated impact before second reading

22


Income Tax• SB 163 and SB 1842– Extends R&D Credit to 1/1/2016

and increases amount from 6.5% to 8% (Referred to Assignments 3/18/2011)

• SB 1215 –Extends R&D Credit until 12/31/2016 (Referred to Assignments 3/18/2011

• HB 2948—Extends R&D Credit until 12/31/2011 plus 5-year Carryforward (Referred to House Rules 3/17/2011)

23


Sales Tax• SB 2194 Sales Tax Sourcing (Re-referred to Rules Committee 5/31/

2011)• Attempts to codify history of regulations and letter rulings issued

by the Department concerning location of where order acceptance occurs for Illinois Retailers’ Occupation Tax

• Amended to provide that if order is first received by the retailer or placed by purchaser at a retailer’s retail sales location and immediate payment and delivery or shipment of property occurs at that location, retail sales location deemed the sales location for the sale

• SB 397 w/HA#1—RTA/IDOR Local Sales Tax Sourcing Proposal (Re-referred to Rules Committee 5/31/2011)

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Property Tax• HB 363 (Re-referred to Rules Committee 7/23/ 2011)

• PTELL Referendum Transparency• HB 503 (Senate Assignments 4/22/2011)

• Municipal Lease of Exempt Property• HB 1883 (Senate Assignments 7/23/2011)

• Stipulated Assessments• SB 19 (Re-referred to Rules Committee 5/31/2011)

• Annual Reapplication for Senior Citizens Homestead Exemption in Cook County

• SB 1648 (Re-referred to Rules Committee 5/31/2011)• Homestead Assessment Freeze Expansion of Disabled

25

Judicial DevelopmentsIncome Tax

AT&T Teleholdings Inc. v. Department of Revenue, 09-COEL-008 (Cir. Ct. Cook County 1/20/2011)

In a Memorandum Opinion and Judgment Order, the Circuit Court affirmed the decision of an Administrative Law Judge that held a capital loss should be allocated among members reporting a capital loss on Schedule D in proportion to the sum of all separate capital losses so as not to result in a windfall by carrying back the loss using a combined apportionment method.

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Judicial DevelopmentsNon-Income Tax

Cwik v. Giannoulias, Ill., No. 108313, 5/20/2010

Issue: Whether the state’s retention of interest accrued on unclaimed property pursuant to § 15 of the Act is an unconstitutional taking of private property without compensation.

Holding: The Illinois Supreme Court held that the state’s unclaimed property statute divests the owner of abandoned property of certain incidents of ownership while that state provides safekeeping of the property along with reclamation services. This limited lapse or divestment is not an illegal taking for which compensation is due.

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Hartney Fuel Oil Co. v. Department of Revenue, Tenth Circuit Court of Illinois, No. 08-MR-11, 08-MR-13, 08-MR15, 1/26/2011

Issue: Whether fuel company provided sufficient evidence to support its position that its fuel sales transactions were sitused at its sales office in the Village of Mark.

Holding: Illinois Circuit Court held that the evidence was sufficient and therefore the local sales tax imposed in Forest View should not have been collected by the Illinois Department of Revenue.

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Empress Casino Joliet Corp. v. Blagojevich, No. 09-3975, 638 F. 3d 519 (3/2/2011)

Issue: Whether casino surcharge imposed by the Illinois legislature and used by the state to assist the horse racing industry is a “tax” to which the federal Tax Injunction Act applies.

Holding: The U.S. Court of Appeals for the Seventh Circuit held the casino surcharge was not a “tax,” but rather more like a regulatory penalty or fee.

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Performance Marketing Association v. Brian Hamer, Director, Illinois Department of Revenue, Cir. Ct. Cook County, 7/27/2011

Complaint originally field in Federal Court, dropped and refiled in Cir. Ct. Cook County challenging the constitutionality of HB 3659 (P.A. 96-1544)(click-through nexus provisions) • Count 1 alleges improper and unduly burdensome regulation of

interstate commerce in violation of the Commerce Clause of the US Constitution

• Count 2 alleges improper regulation of commerce occurring outside of Illinois’ borders in violation of the Commerce Clause

• Count 3 alleges violation of the Federal Internet Tax Freedom Act30


Interstate Trucks, LLC v. State of Illinois, Ill. App. Ct., 4th Dist. No. 4-10-0603 (6/14/2011)Motor Fuel Tax Law

Issue: Whether out-of-state dealership that purchased trucks in Illinois and then attempted to transport the trucks to the dealership in Tennessee was subject to the motor fuel use tax when fuel for the trucks was purchased in Illinois.

Holding: Court held that motor fuel use tax license was not required because, at the time the Department stopped the trucks, they had been operated exclusively within Illinois, and fuel sufficient to get the trucks out of the state had been purchased in Illinois. The court further found that requiring the taxpayer to purchase single-trip permits would not further the purpose

behind the motor fuel use tax.

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Wirtz v. Quinn, Ill. S. Ct., 2011 IL 111903 (7/11/2011), reversing Wirtz v. Quinn, Ill. App. Ct., No 1-09-3163 and 1-10-0344 (1/26/2011)

Issue: Whether four laws enacted in 2009 that created a $31 billion capital program were enacted in violation of the single subject rule of the Illinois state constitution.

Holding: On appeal, the Illinois Supreme Court reversed the Court of Appeals, finding that the substantive provisions of the Act were clearly connected to the single subject of the Act (capital projects) because they established increased revenue sources to be deposited into the Capital Projects fund. Even the provisions that did not directly raise revenue were still related in that they helped implement the other provisions. The Court rejected all other constitutional challenges to the enactment of the Act.

32


Kansas City Southern Railway Co. et al. v. Koeller et al., 7th Cir., No. 10-2333 (7/27/2011)Federal Railroad Revitalization and Regulatory Reform Act (“4-R Act”)

Issue: Whether Sny Island Levee Drainage District assessments were discriminatory under the federal 4-R Act.

Holding: 7th Circuit decision found that the assessment did violate the 4-R Act’s prohibition against imposition of discriminatory taxes when it changed its method for calculating assessments due under the Illinois Drainage Code. While the basis for calculating the assessments (a “benefit basis”) might have been fair in theory, as applied to the railroad companies, it was discriminatory in practice. Case remanded to district court with instructions to enjoin the assessments.

33


Demos v. Pappas et al., Ill. App. Ct., 1st Dist. No. 1-10-0829 (8/15/2011)

Issue: Whether County Treasurer, as judgment debtor under the Property Tax Code Indemnity Fund, is a “governmental entity” for purposes of calculating postjudgment rates.

Holding: The Property Tax Code Indemnity Fund is maintained to satisfy judgments against the County Treasurer, as trustee of the fund. The interest rate applicable to such judgments depends on whether the “judgment debtor” is a “governmental entity.” As trustee of the Fund, the Cook County Treasurer is the relevant “judgment debtor,” and the Court of Appeals determined that the county treasurer is a “governmental entity,” because the treasurer is a constitutional officer carrying out her public duties for the benefit of the public. Therefore, the proper postjudgment rate on indemnity fund judgments is 6%.

34


Regional Transportation Authority v. City of Kankakee et. al., Cir. Ct. Cook County (8/23/2011)

Complaint filed August 23, 2011 alleging that Kankakee and Channahon have been distributing local sales tax revenue to companies sourcing sales to “sham” offices purportedly located in those municipalities. The RTA claims that these “sham” offices are set up to avoid paying locally imposed taxes, including the share of the Retailers’ Occupation Tax that is allocated 0.25% to the RTA in Cook County. As a result, the RTA “loses sales tax monies that should have been rightfully paid to it.” The complaint alleges a violation of 65 ILCS 5/8-11-21, and seeks damages to compensate for the tax revenue it was denied as a result of the municipalities unlawful conduct.

35


City of Chicago v. City of Kankakee et. al., Cir. Ct. Cook County (8/23/2011)

Similar to the RTA action, but limited to periods since 1/1/2004 forward. In addition to damages, City of Chicago is seeking injunctive relief.

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Income Tax Adopted Regulations

Income Tax• Estimated Income Tax Payment

• 86 Ill. Adm. Code 100.8000 and 100.8010, added 8/19/10

• Taxability in Other State• 86 Ill. Adm. Code 100.3200, amended 8/19/10

• Filing Extension Pass-through Entities• 86 Ill. Adm. Code 100.5020, amended 8/19/10

• Income Tax Treatment of Separate Entities• 86 Ill. Adm. Code 100.9750, amended 8/19/10

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Income Tax Adopted Regulations

Income Tax (con’t)

• Electronic Filing Returns and Other Documents• 86 Ill. Adm. Code 760.100, amended 12/21/10 (see slide re:

proposed regs for Notice of further amendments)

• Refund Claims for Overpayment• 86 Ill. Adm. Code 100.9400 and 100.9410, amended 2/25/11.

• Angel Investor Tax Credit• 14 Ill Adm. Code 531.10-.90, adopted 6/1/11

38

Sales/Other Tax Adopted Regulations

Sales Tax• Retailers’ Occupation Tax/Graphic Arts Machinery

• 86 Ill. Adm. Code 130.325, amended 1/24/11• Retailers’ Occupation Tax Candy, Soft Drinks, Drugs, Medicines,

Medical Appliances and Grooming and Hygiene Products as the result of P.A. 96-0034 and 96-0038• 86 Ill. Adm. Code 130.310, amended 8/19/10, and 130.311, added

8/19/10

All Taxes Administered by the DOR• Tax Amnesty

• 86 Ill. Adm. Code 520.101 and 105

39

Department of RevenueProposed Income Tax Regulations

• Electronic Filing of Returns and Other Documents; Proposal to amend 86 Ill. Adm. Code 760.100• Would mandate filing of Illinois corporate income tax

return electronically for those corporations required to file their federal income tax returns, beginning with returns for taxable years ending December 31, 2011

• Formal JCAR meeting 9 /13/2011; 2d Notice ends 10/5/2011

40

Department of RevenueProposed Income Tax Regulations

• Income Tax; Notice of Proposal to amend 86 Ill. Adm. Code 100.7325 (5/27/2011)• Would amend regulation to require semi-weekly withholding payments to

be made by electronic funds transfer beginning calendar year 2011• Income Tax; Notice of Proposal to amend 86 Ill. Adm. Code 100.2101

(6/3/2011)• Would update regulation to reflect changes to the definition of “retailing”

and “tangible personal property” under PA 96-115, and extend the replacement tax investment credit through 2013

• Income Tax; Notice of Proposal to add 86 Ill. Adm. Code 100.2193, .2435, and .2510 (6/10/2011)• Proposes new rules regarding: subtraction modification for contributions

to an Il qualified tuition plan; income tax credit for contributing employers; and addition modification for employers claiming the credit

41

Department of Revenue2011 Regulatory Agenda/ Projects

Income Tax (no hearings scheduled as of 8/29/2011)

• 86 Ill Adm. Code 100 (multiple sections)• Add new rules concerning: tax credit for Tech Prep Youth Vocational

Programs; reallocation of items under Section 404; pass-through of investment credits from partnerships and Sub S corps; filing of refund claims, statutes of limitations and interest computations

• Add and amend rules concerning: computation of base income under Art 2 and the allocation and apportionment of base income under Art 3; definition of unitary business group and computation of combined tax liability of unitary group; addition and subtraction modifications for residential property tax credit; definitions in Section 1501(a); implementation of legislation introduced beginning in 2004; and guidance on nexus and Illinois tax consequences of Federal tax law changes

42

Department of Revenue2011 Regulatory Agenda/ Projects

Sales/Use Taxes (no hearings scheduled as of 8/29/2011)• ROT, 86 Ill. Adm. Code 130: Project relates to multiple sections, including:

• 130.415 transportation and delivery charges• 130.2050 sales and gifts by employers to employees• 130.450 installation, alteration, and special service charges re: real estate• 130.340 rolling stock exemption

• SOT, 86 Ill. Adm. Code 140: Project relates to general updates designed to clarify application of the SOT and to reflect recent decisional law, statutory changes and Dept. policies

• Use Tax, 86 Ill. Adm. Code 150: Project relates to updates designed to reflect new statutory developments, decisional law, and Dept. policies regarding, for example, the types of activities and relationships that establish nexus for Use Tax purposes

• Service Use Tax, 86 Ill. Adm. Code 160: Project designed to reflect new statutory developments, decisional law and Dept. policies

43

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Illinois Department of Revenue Developments

New Tax Computer System• Department in process of completing project to consolidate

more than 200 tax and fee programs into one integrated computer system (four year project begun in 2007)

• Department will have ability to view taxpayer accounts on consolidated basis

• Enhancements to notices and bills (include Account ID for each tax type; Taxpayer Statement to replace Statement of Account)

• Illinois Business Tax (IBT) numbers to be replaced by Account IDs

45

Illinois Department of Revenue Developments

Denial of Property Tax Exemption

• On August 16, 2011, based on the 2010 Illinois Supreme Court decision in Provena Covenant, the Department denied the exempt status of three more Illinois hospitals. The reported charity care at the hospitals ranged from 1.85% of patient revenue to .96%, all in excess of the .07% determined by the court in Provena to be “de minimis.” The hospitals can seek review of the Department’s decision by filing a petition with the Office of Administrative Hearing within 60 days of the Department’s decision.

Other Income Tax Developments

Electronic Filing• Effective January 1, 2011, paid preparers who file more than 100

Illinois Individual Income Tax returns must file electronically

Electronic Payments• Effective October 1, 2010, the mandated threshold for electronic

payments reduced from $200,000 to $20,000 except for Individual Income Tax, Telecom Tax, Environmental Impact Fee, and Motor Fuel Tax

• Effective January 1, 2011, the mandated threshold for making electronic payments for Withholding Income Tax reduced to $12,000

Bonus Depreciation• Department issued revised Form IL-4562• Provides clarification that Illinois conforms with 100 percent bonus

depreciation allowed under Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010

46

Franchise Tax—Illinois Secretary of State

Recent Activity

• BCA 1.35 Allocation Factor Interrogatories—Proposed Apportionment Factor changes

• Business Services Section amended instructions to Interrogatories related to the sourcing of “investment property” and service income

• Significant impact on Illinois Headquarters Companies

• Secretary of State withdrew revised Form BCA 1.35 and reinstated old Form (revised as of Jan. 2003)

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Q&A

• This document is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

• This document was not intended or written to be used, and it cannot be used, for the purpose of avoiding U.S. federal, state or local tax penalties.

• © 2011 PwC. All rights reserved. In this document, "PwC" refers to PricewaterhouseCoopers LLP, a Delaware limited liability partnership, which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.

all that’s new in illinois 12 th annual taxpayers’ federation of illinois state and local tax...

Documents

tax years

development credit

edge credit

replacement tax

enacted legislation

general assembly

corporate income tax

local tax conference