MultiTax Commission

An intergovernmental state tax agency whose mission is to promote uniform and consistent tax policy and administration among the states, assist taxpayers in achieving compliance with existing tax laws, and advocate for state and local sovereignty in the development of tax policy.

Attorney Training Agenda

Attorney Training and Informational Sharing Session

Monday, April 20, 2026 (all times are Eastern Time)

Crowne Plaza Knoxville
401 West Summit Hill Drive
Knoxville, Tennessee

State employees who are not attorneys are welcome to attend in-person the afternoon session of the attorney training on Monday, April 20.  The morning session is open only to public sector tax attorneys. The attorney training is designed to be eligible for CLE credit in most states (except for the Roundtable and Information Sharing Session)—see the MTC’s CLE policy on our website for additional information.

Morning Session

I. Professor Andrew D. Appleby, Winston College of Law (Univ. of Tennessee)
Tax Professor and co-author of Hellerstein on State Taxation, Professor Appleby will address a series of timely SALT topics, including federal preemption/anti-commandeering, data extraction taxes, state taxation of NCTI, and a bit about the process of keeping the Hellerstein treatise up to date.
II.

Effective Trial Objections
Litigation Committee chair Ray Langenberg and other state tax litigators will address the why and how of making objections at tax trials. Panelists will cover timing, possible pitfalls and practical phrasing, and also discuss real-world examples of objections that succeeded and failed.

Presenters: Ray Langenberg—Texas; Brad Young—Arkansas; Hugh McKinnon—Tennessee; Laurel Hall—Tennessee

III. Download from A SALT Leader
Jason Luther, General Counsel of the South Carolina Department of Revenue, will share some of the experience and wisdom he has gained from litigating a series of recent high profile tax cases, discussing issues and challenges that are likely to come to your state.
IV.

Roundtable & Information Sharing Session
MTC roundtable discussions provide a forum for public sector tax attorneys to share ideas and seek guidance from colleagues in other states. For this roundtable, we request attendees to submit by COB Wednesday, April 15, 2026 a brief description of any issues or challenges that may benefit from a group discussion. The objective is to generate a group discussion on the issues or challenges, and discuss possible resolutions or share how those issues or challenges were resolved. We also invite attendees to offer extemporaneous state updates.

Please send your discussion ideas to Ray Langenberg. The roundtable is not eligible for CLE credit in most states.

  Attendees should avoid disclosing confidential or privileged tax information. The roundtable will be open to both in-person and virtual attendees. It is not eligible for CLE credit.

 

Afternoon Session (open to all tax agency staff who will be in Knoxville)

I. Legislative Update with a Focus on State Taxation of NCTI
Carl Davis, Research Director at the Institute on Taxation and Economic Policy (ITEP), will update us on state legislative developments around the country and his expectations about legislation going forward. He will be joined by MTC staff to discuss options available to states to counter tax base erosion that has resulted from international profit shifting and the steps that a growing number of states have taken to tax NCTI (net CFC tested income), a component of the 2025 federal budget reconciliation act.
II.

Data Center Fundamentals
States across the country have amended their laws to specifically address the taxation of data centers. This panel is designed to give tax administrators and their counsel a better understanding of the infrastructure and activities inside data centers, the resources and personnel required to operate them, why some data centers have compartmentalized physical structures, etc. Having a better understanding of data centers will help revenue agencies as they apply their state’s tax laws and develop rules.

Presenters: John Wade—Senior electrical engineer at Oak Ridge National Lab and a lecturer at the University of Tennessee’s Tickle College of Engineering; Shannon Brandt, Tax Policy Counsel, Texas Comptroller’s Office.

III.

Recent Major State Tax Developments
This session will highlight significant recent developments in state tax law and discuss their implications for state tax administration.

Presenters: Bruce Fort and Jonathan White—MTC

IV.

Taxing the Extractive Industry and Related Industries—Part II
This panel will address income tax sourcing of commodity and hedging transactions, interstate sales of natural gas, and revenue from the transportation of natural gas. It also will address whether mineral extraction is manufacturing.

Panelists: Ray Langenberg—Texas; Miranda Scroggins—Louisiana; David Merrien—MTC (and formerly Montana)

    Networking Wind Down

    This informal gathering will be one of many opportunities to build relationships and share ideas with colleagues.

    Dinner

    We will walk to a nearby restaurant for those who would like to join a group for dinner.

    For additional information, contact MTC Counsel, Brian Hamer.

    Back to the 2026 Spring Committee Meeting page.