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The increased exemption may not last after 2012 therefore the question is not whether wealthy taxpayers should act now but rather how transfers should be structured. Application of nexus to sales and income tax New economic nexus provisions Concept of click through and customer location Jennifer Whalley CPA MSA Tax Manager State and Local Tax Group PwC LLP 9 30-10 30 a.m. Nicholas Rochedieu JD Multistate Tax Services Deloitte Tax L.L.P.

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