Byzantine rules reign in the jungle of state and local taxation (SALT). Not only are the laws, regulations, ordinances, court cases and other authority complex, they also overlap. Think of state and local taxation as a three dimensional crossword puzzle – and you might not be too far off the mark. What changes a business implements in one area may save state or local taxes – but beware of the implications in other areas or with respect to other state taxes. The dimensions of our practice are “multi-jurisdictional” and “multi-tax.”
Terminology is often “loose” in SALT practice. For example, a “consolidated return” may be computed as a “combined return” depending on the state; some states base a “franchise tax” on equity, some on income. In some states, states software may be considered tangible personal property, even if delivered electronically – in others, e-transmitted software is by statute tangible (as in Texas.) These dimensions and problems with uniform terminology often lead to mass overpayments – or worse, significant exposures.
With extensive experience in these complex matters, our core competency is in consulting with companies regarding how to manage their state and local tax liabilities. Feel free to call us with questions regarding any aspect of your state and local tax liabilities. Initial consultations are provided at no fee.