The Florida Bar Tax Section’s SALT on the Shore program brought together practitioners from across Florida for a full day of state and local tax education. The event was held in Key Biscayne and achieved the highest attendance for a Florida Bar Tax Section CLE program since the COVID era.  

Attendees included attorneys, CPAs, and tax professionals focused on Florida and multistate issues. The program emphasized applied learning and current developments affecting taxpayers and advisors. Sessions were designed to address both technical rules and practical compliance challenges. 

For those unable to attend, a CLE recording is expected to be available for purchase. Members seeking more information can contact the Florida Bar Tax Section or Jeanette Moffa, Chair of the program. In the meantime, a summary of the topics discussed is below.

Florida Property Tax Procedure and Current Developments

The program opened with a comprehensive review of Florida’s property tax system, examining the constitutional and statutory framework governing ad valorem taxation. The discussion explored the roles of property appraisers, tax collectors, value adjustment boards, and the courts, while also addressing valuation standards, exemptions, classifications, and the procedural requirements that frequently determine the outcome of assessment disputes. Particular attention was given to the strict deadlines applicable to property tax challenges, the burden of proof in litigation, and recent legislative proposals involving homestead exemptions, portability, assessment limitations, and broader property tax relief efforts under consideration in Florida.

Florida Sales and Use Tax in a Changing Economy

The sales and use tax session examined both the fundamentals of Florida’s sales tax system and the increasingly complex issues arising from modern commerce. Topics included taxable transactions, use tax obligations, marketplace facilitator rules, admissions taxation, bundled transactions, and the treatment of various fees and service-related charges. Through practical examples involving delivery charges, gratuities, remote sales, and marketplace transactions, presenters highlighted common compliance risks and audit issues facing businesses operating in Florida. The discussion also explored emerging challenges involving artificial intelligence, streaming platforms, digital goods, and other technology-driven business models, emphasizing the growing tension between decades-old tax statutes and today’s rapidly evolving digital economy. 

Residency and State Income Tax Exposure

The residency session examined the growing state tax challenges created by an increasingly mobile workforce and taxpayer population. Presenters explored the legal standards governing domicile and statutory residency, as well as the factors commonly scrutinized during residency audits, including physical presence, property ownership, family connections, financial records, and lifestyle indicators. The discussion provided practical guidance for managing residency examinations, minimizing the risk of double taxation, and evaluating voluntary disclosure opportunities. Attendees were reminded that residency disputes often turn on detailed factual records, making contemporaneous documentation of a taxpayer’s intent and connections to a jurisdiction critical to a successful outcome.

Florida Corporate Income Tax Fundamentals

The corporate income tax session focused on the challenges businesses face when operating across multiple jurisdictions. Presenters examined nexus standards, apportionment methodologies, and multistate compliance obligations, with particular attention to sourcing rules and the distinction between cost-of-performance and market-based sourcing regimes. The discussion highlighted how evolving business models, remote operations, and digital commerce continue to complicate state income tax planning and compliance. Attendees also explored practical considerations involving entity structure, filing requirements, audit risk, and proactive strategies for managing state tax exposure as states continue to refine and expand their corporate tax regimes.

Florida Documentary Stamp Tax Applications

The documentary stamp tax session examined one of Florida’s most unique and frequently misunderstood tax regimes. Presenters reviewed the application of documentary stamp tax to deeds, notes, mortgages, and other financing instruments, while exploring common real estate transactions, refinancing arrangements, and debt restructurings that can trigger tax liability. Particular attention was given to situations in which documentary stamp tax may apply even in the absence of a traditional transfer of real property. The discussion emphasized the importance of identifying documentary stamp tax issues early in the transaction planning process, as careful structuring and review can help avoid unexpected tax exposure, compliance challenges, and costly mistakes.

Florida Tax Ethics and Professional Responsibility

The final session addressed ethical obligations in tax practice. The program addressed SALT practice on a broad spectrum, from planning and advisory work to audits, controversies, and litigation. Presenters examined issues involving confidentiality, conflicts of interest, privilege, and the duties of candor and disclosure owed to clients, taxing authorities, and the courts. Through a series of practical hypotheticals involving uncertain tax positions and professional judgment calls, attendees explored the balance between effective advocacy and ethical compliance. The session served as a reminder that successful tax practice requires not only technical expertise, but also a strong commitment to professional responsibility and ethical decision-making. 

Looking Ahead for Florida SALT Practitioners 

SALT on the Shore delivered a full day of substantive Florida tax education, bringing together leading practitioners to examine the issues currently shaping state and local tax practice. Strong attendance reflected the continued demand for high-quality CLE programming focused on practical, real-world tax challenges facing Florida businesses, taxpayers, and advisors.

Across sessions covering property tax, sales and use tax, residency, corporate income tax, documentary stamp tax, and ethics, presenters highlighted both longstanding areas of concern and emerging issues driven by technological change, evolving business models, and increased taxpayer mobility. For attendees, the program provided not only technical updates, but also practical insights that will continue to inform planning, compliance, audit defense, and litigation strategies in the months ahead.