An important aspect of our Corporate Tax practice is our multistate and local tax planning, compliance and controversy work. Our extensive multistate experience covers all 50 states and the District of Columbia, and includes virtually all types of taxes, escheat/unclaimed property, and related state regulatory imposts.
Our tax team handles tax work for clients in multiple industry sectors, for traditional entity and individual work, as well as for various hybrid and exotic entities. We also regularly provide tax counsel in multistate economic development and incentive matters, such as corporate relocations, expansions, and multijurisdictional site selection net tax cost comparisons.
Our traditional planning and controversy offerings include audit preparation, management, and defense, administrative and judicial appeals, nexus/reverse nexus work, sourcing planning, and affiliate, attributional, and cross-border tax planning. We also handle less traditional offerings such as voluntary disclosure vs. amnesty, offers in compromise, managed audits, ruling requests, and multidisciplinary, multistate choice of law, reorganizational, and various legislative and regulatory solutions.
We have worked on numerous matters of “first impression” in various states, and have negotiated grants, credits, abatements, and related incentives totaling several billion dollars. In some cases, we have reduced multimillion-dollar assessments to nominal dollars and zero findings and have even secured refunds. Our attorneys have written US and State Supreme Court briefs on tax and tax-related issues, including constitutional issues.
Our multistate and local tax services include:
- Income, franchise, excise, sales/use, property, gross receipts, transfer, bulk sale and telecom taxes
- Multistate nexus, apportionment, sourcing, and other tax planning
- Compliance analysis/counseling
- Multistate tax impact analysis
- Administrative and post-administrative tax controversy work, including audit management and defense
- M&A structural, diligence, and negotiation work
- Entity/reorganizational counselling, including for affiliate and supply chain transactions
- Unclaimed property
- Incorporation/qualification counselling
- Legislative and administrative solutions
- Tax credits, abatements, and other economic development incentives
- Ruling requests, offers in comprise, voluntary disclosure, amnesty
- Unclaimed property
We represent clients across multiple industry sectors, including:
- Agriculture and natural resources
- Aviation, automotive, and regulated transportation
- Construction and real estate
- Economic development and incentives
- Finance and financial/professional services
- Manufacturing, utility, distribution/supply chain
- Not-for-profit and public enterprise
- Retail, wholesale and supply chain