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Core Classes

On the first day of the institute students participate in two core classes that emphasize concepts common to all area of state and local taxation.

Constitutional Law and State Taxation provides an overview of the federal constitutional limits on the state’s ability to tax income and sales including due process, equal protection, privileges and immunities, and commerce clause considerations.  Relevant U.S. Supreme Court cases are covered.

Summary of the Restraints Imposed by the U.S. Constitution

Historical and Current Analysis of Constitutional Restraints on State Taxation

  • The Commerce Clause
  • The Due Process Clause
  • The Equal Protection Clause
  • The Import/Export Tonnage Clauses
  • Supremacy Clause and State Tax Immunity of the Federal Government
  • First Amendment
  • The Privileges and Immunities Clause
  • Taxpayer Remedies for Unconstitutional State Taxes
  • Full Faith and Credit Clause


The Next Century of Constitutional Adjudication

Concepts in Sales and Income Taxes is an introduction and historical overview of the characteristics of state and local taxation, emphasizing the conceptual structure of sales and use taxation and state corporate income taxation and how the underlying logic of these systems can be applied in new settings.  Students will examine the characteristics of state and local taxes and their distinctions with respect to imposition and incidence. Changing definitions of nexus also will be explored.

Sales Tax

  • Definition of Retail Sale
  • Evaluating a Sales Tax
  • Taxation of Services
  • Use Taxes
  • Local Sales Taxes
  • Sales Tax Reform


Corporate Income Tax

  • Conceptual Overview
  • Definition of the Tax Base
  • Apportionment and Allocation of Income
  • Treatment of Intangibles
  • Jurisdictional Issues
  • Uniform Division of Income for Tax Purposes (UDITPA)
  • Combined reports


Faculty members will be Prentiss Willson, Consultant and former Partner, and former National Director of State and Local Tax Practice and Procedure, Ernst & Young, LLP for the class on Constitutional Law and State Taxation; and Richard D. Pomp, Professor of Law, University of Connecticut Law School, for the class on Concepts in Sales and Income Taxes.

Summer Tax Institute

469 Kerr Hall
University of California, Davis
One Shields Avenue
Davis, CA 95616
(530) 752-2183 phone
(530) 752-8666 fax