NEWS & INSIGHTS
COST's Upcoming 57th Annual Meeting in San Antonio
The Council On State Taxation (COST) will host its 57th Annual Meeting in San Antonio, Texas, from September 22–25, 2026. The conference will bring together SALT professionals from across the country to discuss current tax developments, audit trends, and multistate planning issues.Â
COST’s Upcoming 57th Annual Meeting Heads to San Antonio
The Council On State Taxation (COST) will host its 57th Annual Meeting from September 22–25, 2026, at the Hyatt Regency San Antonio Riverwalk in San Antonio, Texas.
The conference brings together state and local tax professionals from across the country to discuss significant SALT developments, audit trends, legislative changes, and multistate tax issues. The program includes sessions covering a wide range of topics relevant to in-house tax departments, practitioners, advisors, and government affairs professionals.
Jeanette Moffa to Speak on Economic Substance and Business Purpose Doctrines
Jeanette Moffa will speak on the panel “Economic Substance and Business Purpose Doctrines in State Taxation” on Thursday, September 24, 2026, from 1:40 p.m. to 2:35 p.m.
The session will examine how states apply economic substance and business purpose doctrines when evaluating tax positions and transactions. Panelists will discuss significant cases, statutory frameworks, enforcement trends, and practical considerations for taxpayers operating across multiple jurisdictions.
The discussion will also include Liberty Global, a closely watched case that continues to generate discussion regarding the role of economic substance principles in tax planning and controversy matters.
Attendees can expect a practical discussion of multistate planning, intercompany transactions, addback regimes, business purpose documentation, and strategies for addressing audit risk. The session is designed to help taxpayers and practitioners better understand how states analyze complex transactions and the factors that often drive audit scrutiny.
Why This Topic Matters
As states continue to scrutinize complex transactions and corporate structures, economic substance and business purpose doctrines remain a significant area of SALT controversy.
Questions involving transaction purpose, intercompany arrangements, and supporting documentation frequently arise during audits. Understanding how states approach these issues can help taxpayers evaluate risk, support tax positions, and prepare for potential challenges.
For practitioners, corporate tax departments, and businesses operating in multiple jurisdictions, the session offers practical insight into an area of state taxation that continues to evolve through legislation, litigation, and administrative enforcement.
Conference Information
The COST 57th Annual Meeting runs September 22–25, 2026, in San Antonio, Texas. Additional information regarding registration, lodging, continuing education credits, and conference programming is available through COST.
Florida State and Local Tax Litigation
Explore our Florida State and Local Tax Litigation. Businesses facing Florida tax disputes should be prepared for the possibility that litigation may continue beyond the trial level. Understanding how tax cases move through Florida’s appellate courts can be critical to protecting favorable rulings and challenging adverse decisions.
© 2025 Jeanette Moffa. All rights reserved.
The COST 57th Annual Meeting is a national conference hosted by the Council On State Taxation that brings together state and local tax professionals to discuss developments affecting multistate taxation.
The conference will be held from September 22–25, 2026.
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The conference will be hosted at the Hyatt Regency San Antonio Riverwalk in San Antonio, Texas.
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The conference is designed for SALT professionals, in-house tax departments, attorneys, CPAs, advisors, and government affairs professionals.
Jeanette Moffa's panel is scheduled for Thursday, September 24, 2026, from 1:40 p.m. to 2:35 p.m.
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The panel will examine how states evaluate tax positions and transactions through economic substance and business purpose doctrines, as well as related audit and planning considerations.
Yes. The session description specifically references Liberty Global as part of the discussion.
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These doctrines can play a significant role in state tax audits, controversy matters, intercompany transactions, and multistate tax planning.
The discussion will address economic substance, business purpose, multistate planning, intercompany transactions, addback regimes, documentation practices, and audit risk.
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Most sessions are open to all attendees. However, the Audit Sessions — which cover recent audit and litigation experiences across various state and local taxes — are open only to COST industry members.
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Jeanette Moffa, Esq.
(954) 800-4138
JeanetteMoffa@MoffaTaxLaw.com
Jeanette Moffa is a Partner in the Fort Lauderdale office of Moffa, Sutton, & Donnini. She focuses her practice in Florida state and local tax. Jeanette provides SALT planning and consulting as part of her practice, addressing issues such as nexus and taxability, including exemptions, inclusions, and exclusions of transactions from the tax base. In addition, she handles tax controversy, working with state and local agencies in resolution of assessment and refund cases. She also litigates state and local tax and administrative law issues.