Carley Roberts

Carley has been the recipient of numerous awards and is regularly featured in the legal profession’s “best of” and “who’s who” lists. In addition to being named as one of the 2016 Top 10 Outstanding Women in Tax for having a significant impact on tax practice and tax policy and 2014 Tax MVP of the Year for having the biggest wins and making the most significant contributions to the state and local tax (SALT) community, she was also recognized as a key influencer in SALT and was featured in the State Tax Today “State Tax Spotlight.”

Carley is past chair of the Taxation Section of the California State Bar. She is known for resurrecting the California Tax Policy Conference–the leading conference on developments in the bellwether state for state tax policy. In addition to being a sought-after speaker, Carley contributes to publications such as Tax Analysts’ State Tax Notes and BNA’s Tax Management Weekly State Tax Report.

• Represents a Fortune 20 technology company in a case of first impression against the City and County of San Francisco involving the exclusion of investment receipts from the Gross Receipts Tax.
• Secured a win before the Pennsylvania Board of Finance and Revenue on corporate net income and franchise tax appeals involving interest expense deductions on behalf of a Fortune 200 consumer food company.
• Secured in excess of $60 million in tax savings in an income tax settlement with the California Franchise Tax Board for a Fortune 50 global health care company.
• Secured use tax refunds in excess of $40 million for a Fortune 50 major telecommunications company on California refund claims involving technology transfer agreements post-Lucent.
• Advised one of the nation’s Fortune 50 largest telecommunications companies at all stages of California tax controversy, from audit, to administrative protest and appeal, to litigation through appellate courts, in matters involving assessments totaling over $250 million.
• Won a California State Board of Equalization appeal for a Fortune 200 communications company on an issue of first impression involving the occasional sale rule for corporate income tax.
• Represents a Fortune 200 financial services company in an action against the California Franchise Tax Board on an emerging issue involving characterization of corporate income.
• Advised a leading Fortune 200 solar technology company on the California sales and use tax consequences of various high-dollar energy transactions.
• Achieved a victory for a Fortune 50 large big box retailer in an action before the California State Board of Equalization challenging the inclusion of treasury gross receipts in the sales factor for corporate income tax purposes that resulted in the California Franchise Tax Board launching a resolution program for all similarly situated taxpayers.
• Secured a win for a Fortune 50 big box retailer in an income tax refund action before the Arizona Tax Court involving the taxability of a REIT dividend.
• Saved a Fortune 50 technology company nearly $30 million in an income tax matter against the California Franchise Tax Board involving sales factor apportionment issues.
• Obtained a favorable California sales tax private letter ruling for a Fortune 200 trucking company involving transfer of title issues for vehicles held in trusts.
• Obtained a favorable California sales and use tax private letter ruling for a Fortune 200 leading industrial gas supplier involving the sales tax consequences of a complex construction project.
• Successfully represented a Fortune 200 media company in an administrative appeal before the City of Los Angeles regarding assessment of the city’s gross receipts tax and utility user tax.
• Successfully represented a Fortune 50 large telecommunications company in utility user tax matters against several California municipalities.
• Won an issue of first impression at the California Court of Appeal in a published decision for a Fortune 50 company confirming that California property tax law does not require a taxpayer assessed on a unitary basis to sue all counties in which it owns property to bring an action in court.
• Successfully resolved California administrative protests for a Fortune 50 multinational health care manufacturer spanning 12 tax years, involving total tax in dispute of over $100 million, and arising from unitary combination, characterization of income, apportionment and credit utilization issues.
• Represented a Fortune 50 retailer in multiple Arizona income tax appeals involving the taxability of a real estate investment trust (REIT) consent dividend, unitary combination and sales factor sourcing.

• Honors & Awards
  • Recipient, Benjamin F. Miller Award (2023)
  • Ranked Band 1 by Chambers USA in the area of State and Local Tax for over a decade (2007 – 2008, 2011 – 2024)
  • Ranked by the Best Lawyers in America guide for Tax Law (2023 – 2025); Litigation and Controversy – Tax (2025)
  • Featured by California Lawyers Association’s “Toast to Women in Tax: Inspiring Leadership” (2022)
  • Named one of Tax Analysts’ “Outstanding Women in Tax” (2016)
  • Named Super Lawyer in the area of Tax by Northern California Super Lawyers (2011 – 2022)
  • Recognized by The Legal 500 U.S. in the area of tax controversy (2015)
  • Recipient of Law360’s “Tax MVP of the Year” (2014)
  • Recipient, V. Judson Klein Award (2013)
  • Recipient, The Wiley W. Manual Award for Pro Bono Legal Services (2005 – 2012)
• Affiliations/Associations
  • External Advisory Committee Member, Office of Tax Appeals (2019 – 2023)
  • Advisory Board Member, Tax Notes State (2020 – 2023)
  • Advisory Board Member, Bloomberg Tax State Tax (2020 – 2023)
  • Advisory Board Member, Paul J. Hartman State and Local Tax Forum (2019 – 2023)
  • American College of Tax Counsel, Fellow of the College (2020 – 2023)
  • Rules Advisory Committee Member, Oregon Department of Revenue (2022)
  • Chair, Taxation Section of the California State Bar (2011)
  • Chair/Chair Emeritus, California Tax Policy Conference (2007 – 2014)
  • Advisor, Executive Committee, Taxation Section of the California State Bar (2013 – 2015)
  • Member, Executive Committee, Taxation Section of the California State Bar (2007 – 2012)
  • Chair, State and Local Tax Committee of the Taxation Section of the California State Bar (2006)
  • Chair, Taxation Section of the Sacramento County Bar (2006)
  • Editorial Advisory Board Member, American Bar Association’s The State and Local Tax Lawyer (2001 – 2005)
• Publications
  • “California OTA Denies Credit for NYC Business Taxes in Precedential Opinion,” SeeSALT Blog Post, with Robert P. Merten III, Jeff Phang and Taylor A.F. Wolff, December 9, 2024.
  • “California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16,” SeeSALT Blog Post, with Robert P. Merten III and Jeff Phang, October 7, 2024.
  • "California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization,” SeeSALT Blog Post, with Jeffrey Vesely, Robert P. Merten III, and Jeff Phang, June 5, 2024.
  • “Reminder: ‘Gross’ Does Not Mean ‘Net’ – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor,” SeeSALT Blog Post, with Robert P. Merten III, Jeff Phang, and Nolan Kessler, April 4, 2024.
  • “Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes,” SeeSALT Blog Post, with Jeff Phang and Robert P. Merten III, March 20, 2024.
  • “California Trial Court Denies FTB’s Motion to Vacate and Modify Judgment that Declared Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid,” SeeSALT Blog Post, with Jeffrey Vesely and Nolan Kessler, February 15, 2024.
  • “California Trial Court Grants Industry Trade Association’s Motion for Summary Adjudication, Declaring Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid,” SeeSALT Blog Post, with Jeffrey Vesely and Nolan Kessler, December 20, 2023.
  • “California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid,” SeeSALT Blog Post, with Jeffrey Vesely and Nolan Kessler, September 21, 2023.
  • “A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain ‘Qualified Tangible Personal Property,’” Pillsbury Client Alert, with Craig Becker, Zachary Atkins, and Richard Nielsen, June 9, 2023.
  • “No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit,” SeeSALT Blog Post, with Jeff Phang, May 17, 2023.
  • “UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT Blog Post, with Jeff Phang and Robert P. Merten III, March 8, 2023.
  • “Property Tax Rate Disputes Merits California Supreme Court Review,” Tax Notes State, with Craig Becker, Breann Robowski, Robert P. Merten III, and Joseph Chan, February 13, 2023.
  • “California Proposes Significant Revisions to Sales & Use Tax Statistical Sampling Audit Policies and Procedures,” SeeSALT Blog Post, with Richard Nielsen and Nolan Kessler, February 8, 2023.
  • “California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT Blog Post, with Robert P. Merten III and Jeff Phang, January 23, 2023.
  • “Texas Court of Appeals Confirms Cost-of-Performance Method Is Proper to Source Service Receipts,” SeeSALT Blog Post, with Evan Hamme and Taylor A. F. Wolff, November 28, 2022.
  • “The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules,” SeeSALT Blog Post, with Jeff Phang, October 24, 2022.
  • “Industry Trade Association Sues California Franchise Tax Board Over “Radical” New Interpretation on Scope of Public Law 86-272 Post-Wayfair,” SeeSALT Blog Post, with Robert P. Merten III and Nolan Kessler, October 10, 2022.
  • “California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable If It Is Classified as Business Income at the Entity Level,” SeeSALT Blog Post with Jeff Phang, June 9, 2022.
  • “Texas Supreme Court Sides with Sirius XM’s ‘Straightforward’ Interpretation of Service Receipt Sourcing Statute,” SeeSALT Blog Post, with Evan Hamme and Taylor A. F. Wolff, March 29, 2022.
  • “Contractual Delivery Terms Control Application of Alabama’s Wholesale Oil License Fee,” SeeSALT Blog Post, with Lexi Louderback, February 15, 2022.
  • “How to Be Reasonable When Reasonably Approximating the Market: Part II,” Tax Notes State, with Robert P. Merten III, Jeff Phang, and Lexi Louderback, December 20, 2021.
  • “California Governor Vetoes Sales Tax Bill Seeking to Require Large Online Retailers to File Informational Reports Detailing Sales by Destination,” SeeSALT Blog Post, with Robert P. Merten III and Jeff Phang, October 7, 2021.
  • “Taxpayer Files Court Action Challenging California’s Proposition 39 (2012) and Its Mandatory Single-Sales Factor Apportionment Formula,” SeeSALT Blog Post, with Robert P. Merten III and Jeff Phang, September 20, 2021.
  • “California’s Long-Awaited Market-Based Sourcing Regulation Amendments: Why Participate in the Formal Regulatory Process?,” SeeSALT Blog Post, September 10, 2021.
  • “California Court of Appeal Says Tax for ‘Public Safety Services’ and ‘Other Essential Services’ Not a Special Tax,” SeeSALT Blog Post, with Lexi Louderback, August 11, 2021.
  • “How to Be Reasonable When Reasonably Approximating the Market: Part 1,” Tax Notes State, with Robert P. Merten III and Malcolm A. Brudigam, January 4, 2021.
  • “California Legislature Passes Governor Newsom’s Proposal to Suspend California Net Operating Loss Deductions and Limit Tax Credits during 2020 – 2022,” Pillsbury Client Alert, with Craig A. Becker, Breann E. Robowski, and Jeffrey M. Vesely, June 24, 2020.
  • “OTA Rules in Precedential Opinion Taxpayer Entitled to Interest Abatement Due to FTB’s Delays in the Protest Process,” SeeSALT Blog Post, April 30, 2020.
  • “COVID-19: Comprehensive Coverage of State Income Tax Relief as of April 13, 2020,” SeeSALT Blog Post, with Robert P. Merten III, and Afshin Michael Khazaeli, April 13, 2020.
  • “COVID-19: Comprehensive Coverage of State Income Tax Relief as of March 29, 2020,” SeeSALT Blog Post, with Robert P. Merten III, March 30, 2020.
  • “California OTA to Host Informal IPM to Discuss Possible Amendments to Rules for Tax Appeals,” SeeSALT Blog Post, March 25, 2020.
  • “COVID-19: IRS and States Extend Tax Payment Deadlines,” Pillsbury Client Alert, with Nora E. Burke, Hannah Hollingsworth, and Mike Le, March 21, 2020.
  • “No Dealer Here: Walmart Walks Away with Big Marketplace Facilitator Win in Creole State,” SeeSALT Blog Post, January 30, 2020.
  • “The CAT is Almost Out of the Bag! Oregon Releases First Set of Draft CAT Rules,” Pillsbury Client Alert, with Robert P. Merten III, December 12, 2019.
  • “‘Interactive’ Website Will Defeat P.L. 86 – 272 Immunity If the MTC Has Its Way,” SeeSALT Blog Post, with Pillsbury SALT, November 11, 2019.
  • “Navigating Local Labyrinths: Practitioners’ Guide to Local Taxes,” State Tax Notes, October 28, 2019.
  • “California Governor Vetoes Ban against Tax Sharing Agreements and Signs New Law Requiring Certain Public Information for Disclosure,” SeeSALT Blog Post, October 15, 2019.
  • “Sunny State Shade: Arizona’s Objection to California’s Tax Reach,” State Tax Notes, with Robert P. Merten III and Mike Le, October 7, 2019.
  • “The California Franchise Tax Board Convenes a Public Meeting on the Gig Economy,” SeeSALT Blog Post, with Pillsbury SALT, October 2, 2019.
  • “California OTA Rejects FTB’s 0.2 Percent Bright-Line Nexus Standard for Out-Of-State Minority Interest LLC Members,” SeeSALT Blog Post, with Pillsbury SALT, September 9, 2019.
  • “Gross! Portland, Oregon, Targets Large Retailers with New Gross Receipts Tax,” SeeSALT  Blog Post, with Pillsbury SALT, June 21, 2019.
  • “California Adopts Marketplace Facilitator Legislation: New Rules,” State Tax Notes, with Jessica Allen, May 20, 2019.
  • “California Governor Signs Marketplace Facilitator Legislation, Preview to New Rules,” Pillsbury Client Alert, with Pillsbury SALT, April 25, 2019.
  • “California Business Tax May Provide High Court Nexus Test,” Law360, with Mike Le, April 16, 2019.
  • “California’s Broad Interpretation of ‘Doing Business’ Attracts More Scrutiny,” Law360, with Mike Le, April 15, 2019.
  • “Taxpayers Benefit from Courts Declining Agency Deference,” Law360, with Mike Le, March 2019.
  • “California Office of Tax Appeals Rejects Franchise Tax Board’s Broad Interpretation of California’s ‘Doing Business’ Standard,” by Pillsbury SALT, November 27, 2018.
  • “Ill-Fated Litigation: Exhausting Administrative Remedies and De Novo Review,” State Tax Notes, with Jessica Allen, November 2018.
  • “Local Sugar Taxes May Be Headed for a Crash,” Law360, with Jessica Allen, August 24, 2018.
  • “California Seeks Input on Clean Energy Equipment Tax Exemption,” Law360, with Robert Merten and Jessica Allen, March 21, 2018.
  • “Implications of the MTC’s Market-Based Sourcing Model Regulations,” State Tax Notes, March 2018.
  • “How States Are Trying New Strategies to Collect Sales Tax,” Law360, October 2017.
  • “Some Observations on Gross Receipts Taxes,” Journal of Multistate Taxation and Incentives, July 2017.
  • “Taxes, Fees and ‘Something Else’: California's Morning Star Decision,” State Tax Notes, June 2017.
  • “Trends and Developments in Alternative Apportionment of State Income,” State Tax Notes, May 2017.
  • “Nortel, Lucent and Taxing Embedded Software in California under a Technology Transfer Agreement,” Journal of Multistate Taxation and Incentives, January 2017.
  • “What New York Can Learn from California’s Combined Reporting History,” with Pilar Mata, Stephanie Do and Kathryn Pittman, State Tax Notes, Vol. 73, No. 13, September 2014.
  • “A Close Shave: California Court of Appeal Rules on Multistate Compact Election,” with Jeff Friedman, Legal Alert, October 2012.
  • “Between a Rock and a Hard Place: Third-Party Enforcement Actions,” with Timothy Gustafson and Jack Trachtenberg, State Tax Notes, Vol. 66, No. 8, October 2012.
  • “Intrastate Apportionment: Ripe for Equitable Relief?,” with Prentiss Willson and Maria Todorova, State Tax Notes, Vol. 65, No. 7, August 2012.
  • “Single Sales Factor Election May Create Exposure to Large Corporate Understatement Penalty,” with Michele Pielsticker, Legal Alert, March 2012.
  • “California Franchise Tax Board’s Financial Institution Record Match (FIRM) Program Gains Traction,” with Jenny Choi, Legal Update, October 2011.
  • “Franchise Tax Board Issues Legal Ruling Regarding Calculation of Net Operating Loss Carryover Periods,” with Tim Gustafson, Legal Update, September 2011.
  • “Storm Shelter: California’s New Voluntary Compliance Initiative,” with Tim Gustafson, State Tax Notes, Vol. 61, No. 5, August 2011.
  • “California Lawmakers Propose Use Tax Reporting Requirements for Out-Of-State Retailers,” with Tim Gustafson, Practical U.S./Domestic Tax Strategies, December 2010, Vol. 10, No. 12.
  • “California’s Current Sales Factor Landscape,” with Tim Gustafson, Legal Update, December 2010.
  • “Assigning Sales of Other Than Tangible Personal Property in California: Emergence of a Market-State-Based Approach,” with Tim Gustafson, State and Local Tax Insights, Spring 2010.
  • “Exploring Revenue & Taxation Code Section 19138: California’s New (and Already Infamous) Corporate 20% Understatement Penalty,” with Tim Gustafson, Lexis Practice Insights Series, June 2009.
  • “FTB to Process Refunds of LLC Fees Based on Ventas Decision,” with Tim Gustafson, Legal Update, May 2009.
  • “FTB Offers 60-Day Period for Taxpayers to Complete Reportable Transaction Disclosure Statements in Order to Avoid Penalties,” Practical U.S./Domestic Tax Strategies, August 2007, Vol. 7, No. 8.
  • “California’s Eagle Lodge West Conference? Tracing Its Roots,” California Tax Lawyer, Spring 2007, Vol. 16, No. 2.
  • “Sales Factor Gross Receipts Cases Addressed by the California Supreme Court,” Legal Update, March 2007.
  • “California FTB Revises Time Goals for Processing Protests,” with Eric Coffill, Legal Update, November 2006.
  • “Gross Receipts and Unitary Credit Issues Ripen after California Supreme Court Acts in Microsoft and General Motors,” Legal Update, August 22, 2006.
  • “California Revenue & Taxation Code Section 24425: Disallowance of Interest Expense Deductions,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 6010.9: Taxability of Custom Computer Software,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 19164: Defending against the Accuracy-Related and Fraud Penalties,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 19308: Filing a Claim for Refund beyond the Normal Time Periods in Section 19306,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 19043.5: Notice of Proposed Adjusted Carryover Amount,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 19322.1: Informal Claims for Refund,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 17016: No Presumption of Nonresidence When the Taxpayer Spends Less than Nine Months in California,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 17951: California Source Income and Its Many Quandaries,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 17014 and Title 18, California Code of Regulations Section 17014: Intent Not Enough to Establish Residency,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Sections 19331 and 19385: When Can a Taxpayer Consider a Claim for Refund Deemed Denied?,” Lexis Practice Insights Series, June 2006.
  • “California Revenue & Taxation Code Section 19322: Filing a Valid Claim for Refund,” Lexis Practice Insights Series, June 2006.
  • “Subpart F Issues under a California Water’s-Edge Election,” State Tax Notes, Vol. 38, No. 8, November 2005.
  • “California 2004 State and Local Tax Important Developments,” The State and Local Tax Lawyer, American Bar Association, Vol. 10, 2005.
  • “An Overview of California’s 2004 Tax Amnesty Legislation,” with Eric Coffill, The Tax Executive, Vol. 56, No. 6, November 2004.
  • “California Enacts New FTB and BOE Penalties Affecting Pending Audits, Protests, Appeals and Settlements,” with Eric Coffill, State Tax Notes, August 2004.
  • “California Residency: Intent Not Enough to Change a Taxpayer’s Residence,” State and Local Tax Insights, Fall 2004.
  • “California 2003 State and Local Tax Important Developments,” The State and Local Tax Lawyer, American Bar Association, Vol. 9, January 2004.
  • “The California and Kansas Legislatures Push the Limits of Quill,” State and Local Tax Insights, Fall 2003.
  • “Kevin Assocs., LLC v. Crawford: Louisiana Court Resists State’s Effort to Expand Reach via Related-Party Transactions,” BNA Tax Management Transfer Pricing Report, June 2003.
  • “Kevin Assocs., LLC v. Crawford: Louisiana Court Resists State’s Effort to Expand Reach via Related-Party Transactions,” BNA Tax Management Weekly State Tax Report, Vol. 2003, No. 15, April 2003.
  • “California 2002 State and Local Tax Important Developments,” The State and Local Tax Lawyer, American Bar Association, Vol. 8, 2003.
  • “Kevin Assocs., LLC v. Crawford: Court of Appeal Rejects Attempt to Tax Delaware Holding Company,” State and Local Tax Insights, Winter 2003.
  • “California 2001 State and Local Tax Important Developments,” The State and Local Tax Lawyer, American Bar Association, Vol. 7, 2002.
  • “California Tax Legislation: Current Developments,” State and Local Tax Insights, Winter 2002.
  • “A Status Report on the California FTB’s Proposed Audit Regulation,” with Eric Coffill, State Tax Notes, Vol. 21, September 2001.
  • “Inconsistent E-Commerce Tax Policies Leave Taxpayers Struggling to Cope,” State and Local Tax Insights, Winter 2001.
  • “California Assembly Bill Proposes Expanded Sales/Use Tax Nexus Rules Affecting Internet Sellers,” with Eric Coffill, Cyberspace Lawyer, July/August 2000.
  • “California 1999 State and Local Tax Important Developments,” with Eric Coffill, The State and Local Tax Lawyer, American Bar Association, Vol. 5, 2000.

• Speaking Engagements
  • “Franchise Tax Board Residency Audits: Anticipation, Preparation, and Resolution,” 2024 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2024, Anaheim, CA.
  • “Mass Appeal: Notable Decisions and Trends at the Office of Tax Appeals,” California Tax Foundation, September 2024, Webinar.
  • “The Ragine Debate over Digital Services Taxes,” COST SALT Workshop for Technology Companies, August 2024, Cupertino, CA.
  • “The Annual Big Easy Brawl,” ABA/IPT Sales Tax Seminar, March 2024, New Orleans, LA.
  • “Foreign Factor Representation,” COST Annual Meeting, October 2023, Las Vegas, NV.
  • “Taxation of the Digital World,” CalTax 97th Annual Meeting, March 2023, Sacramento, CA.
  • “The Income Tax Nexus Battle: Is PL 86-272 dead or dying,” ABA/IPT Advanced State Income Tax Seminar, March 2023, New Orleans, LA.
  • “Let the Countdown Begin! 2022’s Noteworthy SALT Cases,” National Association of State Bar Tax Sections Annual Conference, November 2022, Austin, TX.
  • “California Litigation Update,” California Tax Policy Conference, November 2022, San Diego, CA.
  • “SALT Considerations During an Economic Slowdown,” TEI Annual Conference, October 2022, Scottsdale, AZ.
  • “Top 10 Technology Litigation Cases – Both Transactional and Income,” COST State and Local Tax Workshop for the Tech Industry, August 2022, Burlingame, CA.
  • “Navigating California Income Tax: An Essential Update on the FTB,” CalTax 96th Annual Meeting, June 2022, Sacramento, CA.
  • “Defending against States’ Use of Deference, Substance over Form, & Sham Transaction Doctrines,” COST Sales Tax Conference, March 2022, Las Vegas, NV.
  • “State Treatment of Repatriated Income,” TEI Chicago Chapter Virtual State Income Tax Program, December 2021, Webinar.
  • “Litigation Update,” California Tax Policy Conference, November 2021, San Diego, CA.
  • “An Update on Digital Services Taxes,” 2021 COST Annual Meeting, October 2021, Las Vegas, NV.
  • “How to Navigate the Appellate Process at the OTA,” California Tax Foundation, August 2021, Webinar.
  • “Market-Based Sourcing: Developing a Multistate Approach,” TEI Wisconsin Chapter Meeting, February 2021, Webinar.
  • “Trends in State Taxation,” TEI Year-End Roundup, December 2020, Webinar.
  • “Market-Based Sourcing: Developing a Multistate Approach,” TEI Chicago Chapter SALT Program, December 2020, Webinar.
  • “Protecting Confidentiality & Audit Readiness,” Paul J. Hartman 2020 SALT Forum, October 2020, Webinar.
  • “California Matters – FTB, CDTFA, OTA, Controversy and Legislative Hot Topics,” TEI New York Chapter Meeting, August 2020, Webinar. 
  • “Market-Based Sourcing for Tech Companies: Identifying ‘Customers’ and Locating Their ‘Benefits,’” COST State and Local Tax Webinar for Technology Companies, August 2020, Webinar.
  • “California’s OTA: Friend or Foe?,” TEI Silicon Valley Chapter’s SALT Day & IPT Joint Meeting, December 2019, Santa Clara, CA.
  • “SALT Tax Controversies: Why ‘winning’ isn’t the same for everyone,” TEI Silicon Valley Chapter’s SALT Day & IPT Joint Meeting, December 2019, Santa Clara, CA.
  • “State and Local Tax Issues in Corporate M&A Transactions,” PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Conference 2019, December 2019, Los Angeles, CA.
  • “If You Don’t Know, Now You Know,” Paul J. Hartman State and Local Tax Forum, October 2019, Nashville, TN.
  • “Beware of the Locals – They Might Take You by Surprise,” TEI St. Louis Chapter Meeting, October 2019, St. Louis, MO.
  • “Market-Based Sourcing in a Brave New World,” TEI St. Louis Chapter Meeting, October 2019, St. Louis, MO.
  • “Beware of the Locals – They Might Take You by Surprise,” COST State and Local Tax Workshop for the Tech Industry, July 2019, Foster City, CA.
  • “Taxation of Deemed Repatriation under 965,” COST 2019 Spring Audit Session & Income Tax Conference, May 2019, Denver, CO.
  • “Trends and Developments,” American Petroleum Institute Annual State & Local Income & Franchise Tax Meeting, April 2019, San Ramon, CA.
  • “California Law: The Case of the Overburdened Taxpayer,” California Taxpayers Association’s 93^rd Annual Meeting, March 2019, Sacramento, CA.
  • “The State of State and Local Taxes,” TEI New York State and Local Chapter Meeting, March 2019, New York, NY.
  • “Debt-Related Considerations Arising from the Federal Tax Cuts and Jobs Act,” 2019 National Multistate Tax Symposium, February 2019, Bay Lake, FL.
  • “Federal-State Tax Conformity after the TCJA,” Urban-Brookings Tax Policy Center, How Are States Responding to the Tax Cuts and Jobs Act? January 2019, Washington, DC.
  • “Federal Tax Changes Rocking the SALT Landscape,” TEI New Jersey All Day Seminar, November 2018, Randolph, NJ.
  • “Top Trends in State Income and Indirect Taxes,” TEI Atlanta Chapter Luncheon Meeting, November 2018, Atlanta, GA.
  • “Online Marketplace Operators – The Latest Sales Tax Target,” COST 49^th Annual Meeting, October 2018, Phoenix, AZ.
  • “State Tax Tribunals – Perspectives from Both Sides of the Bench,” COST 2018 Income Tax Conference, April 2018, Boston, MA.
  • “California’s Department of Taxation & Fee Administration and Office of Tax Appeals: What Now?,” TEI Silicon Valley Chapter Meeting, December 2017, Santa Clara, CA.
  • “The SALT Academy Awards,” COST 48^th Annual Meeting, October 2017, Orlando, FL.
  • “State and Local Income Tax Litigation – Cases Not to Miss,” TEI Dallas SALT Day Program, October 2017, Dallas, TX.
  • “Sales and Use Tax Update,” TEI Dallas SALT Day Program, October 2017, Dallas, TX.
  • “Discussion of State Tax Cases and Issues,” COST Mid-Atlantic Regional State Tax Seminar, June 2017, Philadelphia, PA.
  • “Alternative Apportionment – Including Market-Based Sourcing,” COST Mid-Atlantic Regional State Tax Seminar, June 2017, Philadelphia, PA.
  • “The Risks of over Collecting and under Collecting Sales Tax – False Claims Act and Class Action Litigation,” TEI Region II Tax Forum, June 2017, Atlantic City, NJ.
  • “What’s New on the Horizon with State and Local Tax Controversy? Case Developments and Updates,” TEI Los Angeles Chapter Meeting, May 2017, Los Angeles, CA.
  • “An Update on State Tax Considerations of Partnerships and Other Pass-through Entities,” TEI Los Angeles Chapter Meeting, May 2017, Los Angeles, CA.
  • “Spicy Hot SALT – Hot Topics Discussion,” Sacramento County Bar Association Tax Law Section 4^th Annual Tax Symposium, May 2017, Sacramento, CA.
  • “Overcoming the Challenges of State Tax Audit Management,” TEI 2017 Audits & Appeals West: Managing State and Local Tax Controversies, May 2017, Seattle, WA.
  • “State Tax Considerations with Partnerships and Other Pass-through Entities,” Sutherland Tax Roundtable, September 2016, Houston, TX.
  • “Best Practices for Protests and Litigation,” TEI 2016 Audits & Appeals, June 2016, Boston, MA.
  • “The Year in Review – Top Cases,” IPT Annual Conference, June 2016, Traverse City, MI.
  • “The Next Chapter in Transfer Pricing: Transfer Pricing for State Tax,” COST Pacific Northwest Regional State Tax Seminar, November 2015, Foster City, CA.
  • “Transfer Pricing: New State and International Developments,” COST 46^th Annual Meeting, October 2015, Chicago, IL.
  • “The Year in Review,” IPT Sales Tax Symposium, September 2015, Indian Wells, CA.
  • “Ask the Experts – West,” IPT Sales Tax Symposium, September 2015, Indian Wells, CA.
  • “State Income Tax Controversy,” Broadband Tax Institute, September 2015, Colorado Springs, CO.
  • “State Tax Cases, Issues and Policy Matters to Watch – Including Federal Legislation Impacting SALT,” COST Southeast Regional State Tax Seminar, March 2015, Charlotte, NC.
  • “Significant Developments Associated with State Corporate Tax Reform and the Correlative Impact on Our Industry, Including Apportionment, Distortion and Combination,” Broadband Tax Institute, October 2014, Half Moon Bay, CA.
  • “Through a Blurred Lens – Update on State Tax Transparency Developments,” Sutherland Tax Roundtable, October 2014, East Palo Alto, CA.
  • “Nexus: Does Due Process Really Have Teeth or Are the Few Recent Taxpayer Wins a Mere Blip?,” NYU Summer Institute in Taxation, July 2014, New York, NY.
  • “Whirlwind Review of New State Tax Laws,” FTA Annual Conference, June 2014, St. Petersburg, FL.
  • “Best Practices and Strategies for State Tax Controversies and Related Ethical Dilemmas,” TEI Atlanta, June 2014, Atlanta, GA.
  • “Conformity Issues in SALT,” TEI Nashville, May 2014, Franklin, TN.
  • “Conformity Issues in SALT,” ABA/IPT Advanced Income Tax Seminar, April 2014, New Orleans, LA.
  • “Nationwide State Tax Case Developments,” TEI Detroit, March 2014, Dearborn, MI.
  • “Settlement and Litigation: Best Practices and Strategies,” TEI Detroit, March 2014, Dearborn, MI.
  • “Discussion of State Tax Cases, Issues and Policy Matters to Watch – Including Certain Federal Legislation,” COST Southwest/West Regional State Tax Seminar, March 2014, Houston, TX.
  • “Unitary/Combined Filing Developments,” The National Multistate Tax Symposium, February 2014, Orlando, FL.
  • “Special Report – Latest Updates on California Tax Issues,” COST Pacific Northwest Regional Meeting, December 2013, Redmond, WA.
  • “A Rapidly Changing MTC: How It Impacts Sourcing, Apportionment and Taxpayer Audits,” COST Southeast Regional State Tax Seminar, December 2013, Atlanta, GA.
  • “Intangibles: You Can’t Touch but They May Tax,” California Tax Policy Conference, November 2013, San Jose, CA.
  • “Understanding the Intangible,” COST 44^th Annual Meeting, October 2013, Phoenix, AZ.
  • “Top 10 State Income/Franchise Tax Cases and Issues to Watch in 2013,” COST Spring Audit Session/Income Tax Conference, May 2013, New Orleans, LA.
  • “State Tax Exam Issues,” TEI 2013 IRS Audits and Appeals Seminar: Managing Tax Controversies: At Home and Abroad, April 2013, Chicago, IL.
  • “Best Practices and Strategies for Winning California Income and Sales/Use Tax Cases,” COST Pacific Northwest Regional State Tax Meeting, August 2012, San Jose, CA.
  • “California Legal Developments,” Sutherland SALT Roundtable, July 2012, Seattle, WA.
  • “California Technology Transfer Agreements,” Sutherland SALT Webinar, June 2012.
  • “Successfully Engaging the Tax Agencies on Behalf of Your Client,” 2012 California Tax Practitioners’ Conference, May 2012, Los Angeles, CA.
  • “California Shaking – Current Developments,” Sutherland SALT Roundtable, May 2012, Houston, TX.
  • “California Legal Developments,” TEI New York Chapter SALT Committee Meeting, May 2012, New York, NY.
  • “National Sales Tax Developments,” TEI Atlanta Chapter SALT Committee Meeting, March 2012, Atlanta, GA.
  • “Discussion of State Cases and Issues to Watch in 2011,” COST Mid-Atlantic Regional State Tax Seminar, November 2011, Basking Ridge, NJ.
  • “Discussion of State Cases and Issues to Watch in 2011,” COST Southwest/West Regional State Tax Seminar, June 2011, Houston, TX.
  • “California Source Income: Expect Great Scrutiny,” CalCPA Taxation Committee, May 2011, Sacramento, CA.
  • “State Tax Attribute Issues from Merger & Acquisition Activity and Internal Reorganizations,” COST 2011 Spring Audit Session/Income Tax Conference, May 2011, Albuquerque, NM.
  • Multiple White Paper Presentations to IRS, Treasury and U.S. Tax Court, Washington DC Delegation, California State Bar, Taxation Section, May 2011, Washington, DC.
  • “Current State Tax Developments: California and Select Western States,” Annual State & Local Tax Seminar East, April 2011, New York, NY.
  • “Expansion of Franchise Tax Board Rulings to Provide Guidance in Unsettled Areas of Law,” 2011 Eagle Lodge West Conference, attendance by invitation only, April 2011, Santa Rosa, CA.
  • “Best Practices for Winning California Income and Sales/Use Tax Cases,” Seminar Series, February 2011, New York, NY.
  • “The Relevance of the Feds,” TEI-SJSU Tax Policy Conference, February 2011, San Jose, CA.
  • “California’s Current Sales Factor Landscape,” Lexis Tax Law Center, December 2010, Podcast.
  • “Sales Factor Trends and the Impact of Economic Nexus,” 2010 California Tax Policy Conference, November 2010, San Diego, CA.
  • “Recent California Developments,” 2010 Tax Update and Planning Conference, CalCPA Education Foundation, November 2010, San Francisco, CA.
  • “Recent California Developments,” 2010 Tax Update and Planning Conference, CalCPA Education Foundation, November 2010, Universal City, CA.
  • “Sales of Other than Tangible Personal Property: What Does a Shift to Market State Sourcing Mean to Taxpayers?,” COST 41^st Annual Meeting, October 2010, Phoenix, AZ.
  • “Discussion of Latest & Greatest State Tax Litigation,” COST Mid-Atlantic Regional State Tax Seminar, June 2010, Malvern, PA.
  • “Sales of Other than Tangible Personal Property: What Does a Shift to Market State Sourcing Mean to Taxpayers?,” COST 2010 Spring Audit Session/Income Tax Conference, May 2010, Austin, TX.
  • “The Modernization of P.L. 86-272: State Tax Nexus 50 Years Later,” Washington DC Delegation, California State Bar, Taxation Section, May 2010, Washington, DC.
  • “California Current Developments,” Annual State & Local Tax Seminar East, April 2010, New York, NY.
  • “California Current Developments,” TEI, Los Angeles Chapter, March 2010, Universal City, CA.
  • “Discussion of Latest and Greatest California Tax Litigation” and “Western States Nexus Developments,” COST North Atlantic Regional State Tax Seminar, February 2010, Boston, MA.
  • “Update on the California Blue Ribbon Commission Recommendations” and “Discussion of Latest and Greatest State Tax Litigation,” COST Pacific Northwest Regional State Tax Seminar, January 2010, San Francisco, CA.
  • “Update on the California Blue Ribbon Commission Recommendations” and “Discussion of Latest and Greatest State Tax Litigation,” COST Pacific Northwest Regional State Tax Seminar, January 2010, San Jose, CA.
  • “California Tax Update,” 2009 Tax Update and Planning Conference, CalCPA Education Foundation, November 2009, San Francisco, CA.
  • “California Tax Update,” 2009 Tax Update and Planning Conference, CalCPA Education Foundation, November 2009, Universal City, CA.
  • “Fireside Chat with California’s Top Tax Officials,” 2009 California Tax Policy Conference, November 2009, San Diego, CA.
  • “Ethical and Constitutional Issues Related to State Tax Amnesty Programs and Strict Liability Penalties,” Lexis Tax Law Center, June 2009, Podcast.
  • “California Legislative Developments” and “Discussion of Latest and Greatest State Tax Litigation,” COST Pacific Northwest Regional State Tax Seminar, June, 2009, Bellevue, WA.
  • “Discussion of Latest and Greatest State Tax Litigation,” COST Mid-Atlantic Regional State Tax Seminar, June, 2009, Malvern, PA.
  • “New Forms of Coercion or Influence – The Legal Ethics of Penalties Imposed on Taxpayers and Third-Party Intermediaries,” Georgetown University Law Center 32^nd National State & Local Tax Institute, May 2009, Washington, DC.
  • “Franchise Tax Board Settlement and Advance Ruling Process Modifications,” 2009 Eagle Lodge West Conference, attendance by invitation only, May 2009, Santa Rosa, CA.
  • “Select Western States Tax Developments,” Multistate Tax Program, April 2009, New York, NY.
  • “Current California and Select Western States Tax Developments,” Multistate Tax Program, March 2009, San Francisco, CA.
  • “Discussion of Latest and Greatest State Tax Litigation,” COST Pacific Southwest Regional State Tax Seminar, December 2008, Phoenix, AZ.
  • “Sizzling California State & Local Tax Litigation,” 2008 California Tax Policy Conference, November 2008, San Francisco, CA.
  • “See Me, Feel Me, Touch Me … Really? A Multitax Analysis of Tangible Personal Property,” Georgetown University Law Center National State and Local Tax Institute, May 2008, Washington, DC.
  • “California Trust Taxation and Residency Issues,” 2008 Eagle Lodge West Conference, attendance by invitation only, May 2008, Santa Rosa, CA.
  • “State Tax Update,” 2008 Tax Conference, Tax Executives Institute, Portland Chapter, April 2008, Portland, OR.
  • “FTB and BOE Procedural Nuts & Bolts with a Stroll Down Settlement Lane,” 2007 California Tax Policy Conference, November 2007, San Diego, CA.
  • “California Tax Law Simplification Project and FIN 48 Ruling Requests,” 2007 Eagle Lodge West Conference, attendance by invitation only, May 2007, Santa Rosa, CA.
  • “California Franchise Tax Board and State Board of Equalization Developments,” Multistate Tax Program, May 2007, San Francisco, CA.
  • “Costs of Performance: Recent Developments and Trends,” TEI, Los Angeles Chapter, May 2007, Los Angeles, CA.
  • “California Tax Developments,” Multistate Tax Program, April 2007, New York, NY.
  • “California Sales Factor, Dividend Elimination and Payment of Tax Procedural Issues,” 2006 Eagle Lodge West Conference, attendance by invitation only, May 2006, Santa Rosa, CA.
  • “California Excess Tax Reimbursement and Third-Party Rebate Sales and Use Tax Issues,” 2006 Eagle Lodge West Conference, attendance by invitation only, May 2006, Santa Rosa, CA.
  • “State and Local Tax Litigation Update,” 2006 Annual Meeting of the California Tax Bar and the California Tax Policy Conference, November 2006, San Jose, California.
  • “Introduction to California Tax Procedure,” 2006 Annual Meeting of the California Tax Bar and the California Tax Policy Conference, November 2006, San Jose, California.
  • “The Impact of the Fujitsu Decision on Water’s Edge,” 2005 Annual Meeting of the California Tax Bar and the California Tax Policy Conference, October 2005, San Diego, CA.
  • “Franchise Tax Board and State Board of Equalization: Procedural Nuts and Bolts,” California Tax Bar and the California Tax Policy Conference, October 2005, San Diego, CA.
  • “California Tax Developments,” Multistate Tax Program, March 2005, New York, NY.
  • “Current State and Local Tax Developments in California, and California Unitary and Water’s-Edge Issues,” TEI, Los Angeles Chapter, January 2004, Calabasas, CA.
  • “Current State Tax Developments in New York and Other Eastern States,” TEI, Santa Clara Chapter, October 2002, Santa Clara, CA.
  • “Current State Tax Developments in California and Other Western States,” TEI, Portland Chapter, May 2001, Portland, OR.
• Books
  • CEB Advising California Nonprofit Corporations, Sales & Use Taxes (2014, 2015)