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.

Recognition

  • 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.
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