Video

  • 14 minutes

Nexus Issues for Entity Owners, Alter Ego Nexus and Unanswered Nexus Questions

 
Our speaker, John Barrie, reflects on the question that comes up all the time - are the out-of-state owners subject to tax? Mr. Barrie explains that states have addressed this in a couple ways. One way it that they have required withholding at the entity level of income paid to out-of-state members; and another way is to require the out-of-state members to sign a consent agreeing to pay tax in the state which waives the nexus issue. He reviews another concept called an alter-ego nexus, also known as an affiliate nexus, which poses the question of a parent company being allowed to create nexus for an affiliate or subsidiary. To conclude this video Mr. Barrie discusses unanswered nexus questions.

John P. Barrie is a partner in the Washington and New York offices of Bryan Cave LLP. His practice focuses solely in the areas of federal and state tax controversy and transactional matters. Mr. Barrie regularly represents taxpayers in state sales/use tax and state income tax controversy matters. His transactional practice includes providing tax advice to public and private businesses in taxable and tax-free mergers, acquisitions, reorganizations, spin-offs, divestitures and restructurings.
Runtime: 14 minutes

Faculty

John P. Barrie

John P. Barrie

Bryan Cave Leighton Paisner LLP

Agenda

Faculty

John P. Barrie

John P. Barrie

Bryan Cave Leighton Paisner LLP

  • Partner in the Washington and New York offices of Bryan Cave Leighton Paisner LLP
  • Practice focuses solely in the areas of federal and state tax controversy and transactional matters
  • Regularly represents taxpayers before IRS Appeals Offices and the United States Tax Court
  • Transactional practice includes providing tax advice to public and private businesses in taxable and tax-free mergers, acquisitions, reorganizations, spinoffs, divestitures and restructurings
  • Former attorney-advisor, Judge Leon Irwin, United State Tax Court
  • Adjunct professor in the graduate tax program at Georgetown University Law Center, where he has taught courses in reorganizations and corporate tax planning and at New York Law School where he has taught courses in corporate tax planning, s-corporations and tax court litigation
  • Fellow of the American College of Tax Counsel
  • Listed in Best Lawyers of America and Super Lawyers
  • J.D. degree, University of California-Hastings; LL.M. degree in tax, New York University; B.A. degree, University of California-Los Angeles

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