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Practice Leaders

State & Local Tax (SALT)

State and local taxes impact all businesses, regardless of size, industry or entity structure, and are constantly changing (almost daily) due to new legislation, court cases and rulings, or simply a state department of revenue changing their interpretation of current law. Additionally, the lack of uniformity of among the states creates a maze of confusion resulting in the risk of underpaying or overpaying tax.

FD SALT specializes in serving emergent start-up companies, middle market companies, private equity owned companies, and foreign-owned companies so they can adapt to state tax law change and complexity, and achieve their business goals in a state tax-efficient manner.

FD SALT assists companies in identifying and taking advantage of state and local statutory credits and discretionary incentives, and delivers services related to the following tax types: income tax, franchise tax, gross receipts taxes (such as the Ohio Commercial Activities Tax, Washington Business and Occupation Tax, Oregon Corporate Activity Tax, Tennessee Business Tax, Nevada Commerce Tax, Virginia Business, Professional and Occupational License Tax), sales and use tax, personal property tax and real estate transfer tax.

Meet the Partner-in-Charge of State & Local Tax

In this video, Brian Strahle introduces himself and key aspects of FD SALT.

Watch now to learn more

 

Income Tax, Franchise Tax and Gross Receipts Tax Services may include:

  • Nexus Review
  • Sales Sourcing Analysis
  • Apportionment Review (factor analysis, allocation vs. apportionment; alternative apportionment)
  • Filing Method Analysis (separate, unitary, combined or consolidated)
  • Tax Base Review (IRC conformity, unique state modifications, etc.)
  • Pass-Through Entity Filing Review (PTE election analysis compared to nonresident withholding / composite filing)
  • Voluntary Disclosure Agreement (VDA) negotiation
  • M&A Due Diligence (buy or sell side)
  • Related Party Transaction Analysis (transfer pricing, restructuring, modeling, what-if scenarios)
  • Net Operating Loss Management, Preservation and Utilization Study
  • Audit Defense and Administrative Appeals Representation
  • Penalty Abatement Requests
  • Private Letter Ruling Requests
  • ASC 740 Consulting (uncertain state income tax positions analysis and review)
  • State Revenue Agent Report (RAR) Compliance
  • Credits and Incentives Review

Sales & Use Tax Services may include:

  • Nexus Review
  • Sales Sourcing Analysis
  • Sales Taxability Studies (taxability of sales and/or purchases; matrix development and maintenance)
  • Exemption Review (for both sales and purchases)
  • Voluntary Disclosure Agreement (VDA) negotiation
  • Audit Defense and Administrative Appeals Representation
  • Penalty Abatement Requests
  • Private Letter Ruling Requests
  • M&A Due Diligence (buy or sell side)
  • ASC 450 Consulting (uncertain sales tax positions analysis and review)
  • Credits and Incentives Review
  • Training Sessions

Personal Property Tax Services may include:

  • Exemptions Review
  • Economic Obsolescence Analysis
  • Functional Obsolescence Analysis
  • Asset Classification Review

Learn More:

Tennessee Capitol Building

SALT ALERT: Tennessee Proposes Major Changes to Franchise Tax

On January 24, two Tennessee House Republicans introduced House Bill (HB) 1893. As introduced, HB 1893 deletes the provision requiring that the measure of the franchise tax must not be less than the actual value of the real or tangible property owned or used by a taxpayer in Tennessee.

Despite Recent Attacks, P.L. 86-272 Can Still Protect Your Company | Frazier & Deeter

Despite Recent Attacks, P.L. 86-272 Can Still Protect Your Company

P.L. 86-272, a federal law that many companies rely on to protect them from having to pay a state’s income tax, has been under attack by the Multistate Tax Commission since 2018. Despite these attacks, the law can still offer valuable protection for businesses engaged in interstate commerce.

Practice Leaders

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