With the state-by-state march to undermine Public Law 86-272 underway, find out whether taxpayers can find a safe harbor in Public 86-272 at this ABA-IPT Advanced State Income Tax Seminar, with Moderator Judy Vorndran and Panelists Jennifer Karpchuk and Carley Roberts.


The Income Tax Nexus Battle: Is Public Law 86-272 Dead or Dying?

March 14, 2023 | 9:30 – 10:30 am CT

Public Law 86-272 was enacted on September 14, 1959 — that is a LOOOONGGG time ago! The Multistate Tax Commission (MTC) revised its Revised Statement on Public Law 86-272 during 2021 and states are starting to consider adopting some or all of the MTC’s “guidance”. California published new administrative guidance modifying how it applies Public Law 86-272 that substantially broadens the definition of nexus particularly for internet-based companies. There are other states with similar changes in the works — statutorily and through regulation or administrative changes or, worst of all, on audit. Examples in the new California technical advice memorandum explain when businesses may or may not be exceeding the protections of Public Law 86-272.

Learning Objectives

After attending the session, the participant will be able to:

  • Explain the history and reason for changes to Public Law 86-272
  • Manage state and taxpayer expectations
  • Identify what is still protected under this federal law
  • Summarize successor liability laws


Judith B. Vorndran, JD, CPA, Partner | TaxOps SALT, LLC | Golden, Colorado


Jennifer W. Karpchuk, Esq. | Shareholder | Chamberlain Hrdlicka | West Conshohocken, Pennsylvania

Carley A. Roberts, Esq. | SALT Partner | Pillsbury Winthrop Shaw Pittman LLP | Sacramento, California

About the 2023 ABA-IPT Conference

The Institute and the ABA Section of Taxation will once again host the three annual jointly-sponsored Seminars – one in Sales Tax, Property Tax and State Income Tax.  Join practitioners from around the country for one or more of these Seminars that will feature the latest developments and current issues in the state and local tax field.  

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