Learning from the Bloomberg Tax 2019 State Trust Nexus Survey

December 11, 2019 at 1:00 PM

In Bloomberg Tax’s 7th annual Trust Nexus Survey, senior state tax officials answered questions addressing their general trust income tax policies, the constitutional limitations placed on their taxation of trusts, the taxation of nonresident and part-year resident trusts, the availability of credits for taxes paid to other states, state-source income for nonresident trusts, and the specific activities that determine whether a trust is taxed as a resident trust in their state.

With the lack of uniform trust residency laws across the states, double taxation becomes a concern for all those involved with the creation and administration of a trust. When a trust is a resident trust under a state’s law, the state may tax the trust’s entire income. Because trust residency laws vary greatly among the states, a trust may be considered a resident trust in more than one state. As a result, the trust is subject to tax on its entire income in multiple states.

This webinar covers the results of the Bloomberg Tax 2019 Trust Nexus Survey and examines broad trends that emerge through the states’ responses.

Educational Objectives:

  • Know the latest developments and trends regarding trust income tax nexus
  • Identify the types of activities, which by themselves, might be sufficient to subject a trust to income tax as a resident trust in a state
  • Understand the legal theories upon which the emerging state nexus doctrines are based, including the theories advanced in Kaestner and Fielding
  • Anticipate the nexus claims that may arise as a result of certain types of activities
  • Compare the types of nexus policies adopted by the different jurisdictions

Who would benefit most from attending this program?
Executives, business leaders, state tax & finance professionals, tax counsel, and executives working on state tax issues.


Lauren E. Colandreo

  • State Law Tax Editor
  • Bloomberg Tax & Accounting

Lauren Colandreo is a Senior State Tax Law Editor with Bloomberg Tax, where she analyzes recent changes in state tax law, develops new products and maintains existing products, including Bloomberg Tax’s practice tools, navigators and portfolios. Lauren also contributes to the Daily Tax Report: State, SALT Talk blog and co-authors an annual special report analyzing the key factors driving state income taxation of trusts.  Lauren’s 2013 report won the 2014 Gold Regional ASBPE Award of Excellence for Original Research. She holds a B.S. and a B.A. from Salisbury University, a J.D. from the Columbus School of Law at the Catholic University of America and an LL.M. in Taxation and Estate Planning Certificate from the Georgetown University Law Center.

Raj A. Malviya

  • Partner
  • Miller Johnson

Raj A. Malviya, J.D., LL.M (Tax), is a partner in the Private Client practice group at Miller Johnson, and he practices in all areas of domestic and international trust and estate administration and tax planning.  Mr. Malviya is a former Fellow of the American Bar Association’s Section of Real Property, Trust & Estate Law Section and is a Fellow of the American College of Trust and Estate Counsel (ACTEC), where he serves as a member of the Fiduciary Income Tax Committee and International Estate Planning Committee.  He is recognized in Best Lawyers of America, Michigan Super Lawyers and Chambers High Net Worth Guide.  Mr. Malviya regularly speaks and publishes on a variety of tax and estate planning aspects of the private client practice.

Edwin P. Morrow III

  • Eastern U.S. Wealth Strategist
  • U.S. Bank, Private Wealth Management

Ed Morrow is a Wealth Strategist for U.S. Bank Private Wealth Management and works with wealth management teams focusing on the Eastern U.S., advising high net worth clients on how to preserve and transfer their wealth. Ed was previously in private law practice in Cincinnati, Ohio concentrating in taxation, estate and business planning.  Other experience includes drafting court opinions for the U.S. District Court of Portland, Oregon as a law clerk. Ed has his Juris Doctor (J.D.) from the Northwestern School of Law at Lewis and Clark College in Portland, Oregon.  He has a master’s degree in business (MBA) from Xavier University in Cincinnati and a master’s degree in tax law (LL.M) from Capital University in Columbus, Ohio. Ed is a board certified specialist in estate planning and trust law through the Ohio State Bar Association and is a Fellow in the American College of Trust and Estate Counsel.  He is also a Certified Financial Planner (CFP®).  He is a frequent writer and speaker on wealth management, tax and asset protection topics nationwide and is a co-author with Steve Leimberg, Paul Hood, Jay Katz and Marty Shenkman of Tools and Techniques of Estate Planning, 18th Edition.

Walter Pickhardt

  • Senior Counsel
  • Faegre Baker Daniels LLP