P.L. 86-272 in Today’s Economy – How Much Protection is Left?


Marji L. Gordon-Brown, MacAndrews and Forbes, Incorporated


  • David Brunori, RSM US LLP
  • Brian A. Hamer, Multistate Tax Commission
  • Jamie C. Yesnowitz, Grant Thornton LLP
  • Mark W. Yopp, Baker McKenzie

Does P.L. 86-272 provide any practical protection for taxpayers In a modern economy dominated by services and intangibles? This panel will discuss the tools that the states are using to attack claims of P.L. 86-272 protection. The panel will also discuss how some modern practices can put your claim of P.L. 86-272 protection at risk.

Learning Objectives: After this session, attendees will: (1) understand the historical backdrop for PL-86-272, (2) ascertain how its application has shifted over time, and (3) identify issues and opportunities associated with invoking its protection.

Location: Date: March 24, 2021 Time: 3:45 pm - 5:00 pm