State Tax 2018 S tate Tax Prac ctice Re eed Smith h’s State T Tax Practi ice has m more profe essionals s exclusive ely focuse ed on sta ate tax iss sues than n any oth er U.S. law w firm. D Devoted to o the full range of f state tax x matters s, we do m more than n address s individu ual issues s as they a arise. Ou r em mphasis is s on build ding stron ng client r relationsh hips, so w we work t to create co mprehen nsive solu utions tha at enable our clien ts to focu us on mo ving ahea ad. Ree ed Smith’s sta ate tax lawyer rs serve client ts by leveragin ng and Un nclaimed Prop perty. We ass sist clients wit th state tax a na ational platfo rm with deep p tax technica al and industr ry controv versies at the e audit level, a and represen nt clients at exp perience. Our r lawyers have e diverse bac kgrounds, all adm ministrative lev vels, federal a and state cou urts, allo owing us to un nderstand mo ore about ou r clients and includin ng the United d States Supr reme Court. B Because we the ir needs, and d not solely th he laws impac cting them. Th his unders stand that it is s more cost e effective for c lients to dep pth and bread dth of knowle edge impacts how we conclud de a matter a as early as po ossible in the controversy add dress client is sues – balanc cing the law a against the proces ss, we work di iligently to ac hieve favorab ble eco onomic, busin ness, and soci ial environme ents in which settlem ment. As need ded, we will de efend clients through all our r clients work every day. judicial l levels until o our clients’ go oals are met. Our r approach h as resulted in n our represe entation of Tax Co onsulting. Ou ur consulting work mirrors s the mo re than 10 pe ercent of the Fortune 500 companies in n subject t-matter expe erience of ou r controversy y and stat te tax matters s, and recogn nition by tax a and business litigatio on work. Our ability to deliv ver consultin g work org ganizations, in ncluding The W Wall Street Jou rnal . differen ntiates our se ervices from m many other la aw firms. Our se rvices include e:. Rec cently we wer re named one e of 2016’s Ta ax Practice Gro oups of the Ye ear by Law 36 60 . Our state tax attorneys s • Perf forming mult tistate tax refu und reviews wer re also recogn nized by both h Chambers U USA and Legal • Mod deling multist tate impact o of changing ta ax laws and 500 0 in their 2017 7 rankings. bus siness facts Fee e Flexibilit ty & Cost S avings. • Dev veloping and implementing g state tax m inimization stra ategies for tra ansactional ac ctivity or gene eral tax Our r practice offe ers a flexible approach to billing and fe es. liab ilities We have the abi lity to structu ure matters ba ased on • Con nducting and documenting g FIN 48 revie ews con ntingency-bas sed billing, ris k-sharing agr reements, and d • Mon nitoring and a advocating le egislative, regu ulatory and oth er arrangeme ents tailored to meet clien nt needs and othe er legal deve lopments inte ernal corpora te policies. • Dra fting legislatio on and regula ations Sco ope of Serv vices • Iden ntifying, nego otiating and im mplementing credits and Our r services inc lude not only y traditional le egal services o of ince entives aud dit defense an nd appeals – litigating from m the earliest of • Dev veloping uncla aimed prope rty reporting positions adm ministrative le evels all the w way through to o the United Stat tes Supreme Court – but a also nearly all l areas of tax • Dev veloping com pliance progr rams con nsulting. • Exe cuting volunt tary disclosur re initiatives Con ntroversy & Litigation. O Our controver sy and litigati on • Obt taining ad val orem tax exe emptions, incl luding wor rk encompass ses all states and all taxes , with particu lar thro ough appeal em phasis in inco ome/franchis e tax, sales/u se tax, • Ass isting with pu ublic relations s issues result ting from rea l/personal pr roperty tax, an nd gross rece eipts taxes, tax matters suc ch as the Texa as Margins Ta ax and Washin ngton B&O,
Highlighted Tax Services Success Stories The following services are not representative of all tax • Rare Victories for Intangible Holding Company consulting, controversy and litigation services provided Structures. Prevailed in resolving numerous cases by Reed Smith’s State Tax Practice, and highlight only a involving the intangible holding company of a major few of the services for which our clients engage us: nationwide retailer and entities. Similarly helped several clients facing tax exposures of tens of millions • Tax Refund Reviews. We have a record of success in of dollars in New Jersey in a dispute involving obtaining significant cash refunds and future tax intangible holding companies. savings using a contingency-fee structure, so that we take on the risk of failure and our clients incur no fees • Record Settlements for Industry and Individuals. unless we succeed. Our Refund Review Program is Obtained the largest income tax refund settlement performed for all state income/franchise tax returns, for a bank taxpayer; large settlements for a sales/use tax returns, and gross receipts taxes, such pharmaceutical company in Illinois; some of the as the Texas Margins Tax and Washington B&O. largest oil and gas company cases to come before the Notwithstanding the ever-vigilant work of taxpayers to California Franchise Tax Board; and helped settle the correctly report taxes and maximize tax savings for largest personal income tax residency case. the company, opportunities always remain for tax • Legislative and Regulatory Guidance. Facilitated a savings. Our lawyers can identify positions based on meeting between a top New Jersey official and clients case law, administrative policy, or legislative changes following passage of the state’s Business Tax Reform that may support a refund of taxes paid. Act. The meeting provided the opportunity to gain • Controversy and Litigation. Reed Smith’s State Tax valuable insight as to how the new act would be Group is recognized for its ability to effectively litigate interpreted. We then helped position our clients and win controversies. At the same time, we have an advantageously under the new act. efficient approach to case management. For example, • Nationwide Resolution. Developed and executed a we have created a number of taxpayer coalitions to 50-state resolution strategy for a Fortune 100 share the costs and burdens of litigation, including company in addressing state actions aimed at one coalition that funded the appeal of a taxpayer intangible holding companies. Strategy eliminated with sympathetic facts for the benefit of all taxpayers nearly $100 million of potential tax exposure by in the coalition. participating in early voluntary compliance programs, • Mergers, Acquisitions & Transactions. Our team pursuing amnesty opportunities, negotiating provides tax counsel for pre-and post-transaction favorable settlements, and assisting with analysis of phases of buy or sells transactions, including due Uncertain Tax Positions. diligence assistance with transfer, sales/use, property, • Public Relations. Represented one of the 10 largest employment, and other taxes. We identify structural U.S. banks in a state tax case that received media alternatives to minimize costs or enhance tax savings, attention. Working with the bank’s tax team, its and regulatory requirements that may affect closing general counsel office, and our public relations team, terms. We also identify opportunities to reduce state we obtained subsequent media coverage that was fair tax exposures or obtain refunds, and whether to do and balanced. so before or after the transaction. • Refund Reviews. Acted as national sales tax counsel • Credits & Incentives. Our team has experience in all for a major information services provider, obtaining phases of the credits-and-incentives life cycle, and is significant refunds of tax paid on millions of dollars’ called to discuss C&I issues at national and regional worth of software purchases. conferences. We have been involved in the identification of credits and incentives, contract • Sales/Use Taxation and Cloud Computing. Advised negotiations, drafting tax credit agreements to a major manufacturing company, which initially had maximize cash benefits and minimize risks – including decided against pursuing a tax issue that appeared to public reputation risk – and implementing the C&I be relatively small. Our attorneys reviewed the awards across corporate functions to ensure a company’s return and uncovered a larger issue. We successful audit of the award. took the claim to Pennsylvania’s administrative board and obtained a decision that resulted in substantial immediate and future savings. • Groundbreaking Use of Offsetting Credits . Litigated a ground-breaking case establishing the affirmative duty of Pennsylvania auditors to find and allow credits as offsets to any assessed sales tax.
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