State & Local Tax

We use a strategic approach and detailed state and local tax planning skills to help our clients manage risk and seize opportunities.

Our approach

State and local taxes can add up and cut deeply into a company’s bottom line.

Our State and Local Tax (SALT) practice operates on a nationwide basis and boasts attorneys with experience in most states. Our strong contacts with high-ranking individuals in the various state taxing authorities as well as our counsel prove invaluable to both established and new technology businesses alike.

We have the detailed state and local tax knowledge and hands-on experience to handle almost any case—whether it’s assisting a client on audit defenses, administrative appeals and civil tax cases in state courts; companies dealing with income, sales/use, property and payroll tax compliance obligations in multiple jurisdictions; or a high net worth individual living in multiple jurisdictions.

SALT controversies and litigation

From controversies and litigation to planning and risk management advisory services, we help clients with:

  • Nexus
  • Apportionment methodology, including sales factor sourcing
  • Transfer pricing
  • Add-back of intercompany expenses
  • Forced combination
  • Unitary group determinations
  • Tax treatment of mergers and acquisitions
  • Sales/use tax exemptions
  • Eligibility for credits and incentives
  • Pass-through entities
  • Tax treatment and disclosure of reportable transactions
  • Voluntary disclosure agreements
  • Penalty abatement
  • Responsible person liability
  • Unemployment insurance
  • Abandoned property
  • Property tax exemptions
  • Realty transfer taxes

Who we work with

  • Financial institutions
  • Multistate corporations
  • Private clients
  • Middle-market businesses (technology, biotechnology, media, health care, etc.)
  • Manufacturing companies
  • Operating businesses
  • International corporations
  • Individuals in the U.S. and abroad
  • Insurance companies
  • Nonprofits
  • Private equity/venture capital firms

Recent Experience

  • City of Winchester v. Am. Woodmark Corp., 464 S.E.2d 148 (Va. 1995).
  • Comptroller of the Treasury v. Gannett Co., Inc., 741 A.2d 1130 (Md. 1999).
  • Dept. of Revenue v. Dyncorp, 14 P.3d 981 (Alaska 2000).
  • Gen. Motors Acceptance Corp. v. Dept. of Assessments and Taxation, Case No. 13-C-01-50264 (Cir. Howard Co. Md. 2003).
  • Gen. Motors Corp. v. Com., Dep’t of Taxation, 602 S.E. 2d 123 (Va. 2004).
  • In Re Peter Pan Bus Lines, Inc., Determination Dta. Nos. 819131 and 819132 (N.Y. Tax App Trib. 2005).
  • T-Mobile USA, Inc. v. Dept. of Fin. for Baltimore City, 2006 WL 1976188 (Md. Tax. 2006).
  • Fleet Nat. Bank v. Comm’r of Revenue, 862 N.E.2d 22 (Mass. 2007).
  • Crusader Serv. Corp. v. Godwin Ave. Urban Renewal, 2009 WL 3762452 (N.J. Super., 2009).
  • Int’l Paper Corp. v. Va. Dep’t of Taxation, (Va. Cir., June 2010 (unreported)).
  • W. L. Gore & Assocs., Inc. v. Comptroller of the Treasury, 2010 WL 5927989 (Md. Tax. 2010) and (Md. Circuit Appeal 2011).
  • In Re Trugreen Ltd. P’ship, Determination Dta. Nos. 822258 and 822499 (N.Y. Div. Tax App. 2010).
  • Planning—Developed and negotiated an alternative apportionment methodology with state tax authorities that significantly reduced a company’s effective tax rate
  • Governmental Affairs—Drafted proposed state legislation for tax credits relating to the solar industry
  • Risk Management—Coordinated an internet retailer’s response to “Amazon” legislation and case law in multiple jurisdictions
  • Financial Reporting—Assisted a financial services firm to assess and report its state income tax risks in its financial statements (i.e., FIN 48 analysis)
  • Planning—Designed and implemented a strategy to effectively manage state income taxes in Florida, Massachusetts and Minnesota for an individual who anticipated a significant amount of deferred compensation that should result in more than $1 million of savings.
  • Risk Management—Outlined a plan to minimize the risk of double taxation for an individual with homes in California, Georgia and Massachusetts, by determining appropriate state filings for such individual and proposing non-invasive lifestyle changes in view of potential audits by state taxing authorities.
  • Controversies—Successfully represented a client against a $900,000 claim by the Georgia Department of Revenue, which was asserting residency over an individual domiciled in Massachusetts.


  • Recommended as one of the “leading tax firms in the world” in the 6th edition of Tax Directors Handbook 2012, compiled by the publishers of The Legal 500 and Legal Business Magazine.

Federal Estate Tax Law Changes Are Possible in Biden Administration

Rochester Business Journal | December 18, 2020

Rochester Private Clients partner Stephanie Seiffert was quoted in this article for her outlook on estate taxes amid the pandemic and end-of-year best practices for estate planning.

Should You Be in a Hurry to Make Gifts Before the End of the Year

Rochester Business Journal | December 18, 2020

Rochester Private Clients partner Stephanie Seiffert contributed this article for her outlook on estate and gift tax strategies amid the incoming Biden administration, from a state and federal perspective.

ATB clarifies tax method for ‘entry fee communities’

Massachusetts Lawyers Weekly | August 22, 2019

Boston Affordable Housing and Real Estate partner Jeff Sacks wrote this contributed article analyzing a ruling by the Appellate Tax Board on the proper method of determining real estate taxes for senior living facilities that use an entry fee model. Boston law clerk Thomas Jackson contributed to the article.

How federal tax reform has impacted real estate | May 20, 2019

Los Angeles Public Finance and Project Finance partner Rudy Salo says the impact of federal tax reform, which included a $10,000 cap on the deduction for state and local taxes, on the real estate market has not been as dire as predicted.

Vendere impianti, attrezzature e macchinari in USA: direttamente o tramite la propria filiale statunitense?

Wolters Kluwer’s Fiscalità Commercio Internazionale | February 12, 2019

In this contributed article to Wolters Kluwer’s Italian business publication, Chicago Corporate partners Chuck Bernardini and Frank Emmons discuss state and federal tax, customs and corporate considerations for an Italian manufacturer exporting plants, equipment and machinery to the USA, particularly whether to do so directly or through a U.S. subsidiary.

Issues to Watch: 18 of the biggest policies and problems legislatures will confront in 2019

Governing | January 01, 2019

Los Angeles Project Finance and Public Finance partner Rudy Salo is quoted in this article discussing how taxpayers across the country are likely to pay higher bills this April due to the new $10,000 cap on federal deductions for state and local taxes.

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