THE 'GAME' KEEPS CHANGING
Multistate tax laws are so complicated that businesses are set up to fail, to be exposed to audit assessments, to miss out on refunds due to expired statute-of-limitations, pushed to appeal assessments because of unreasonable positions by department audit divisions, coerced to pay computer generated notices simply because the cost of fighting outweighs the benefit. Forced to obtain elaborate accounting software, put procedures in place to comply, and hire experts to plan to minimize tax and mitigate the risk of exposure. The compliance burden for multistate businesses is overwhelming.
State statutes and regulations, court cases, rulings, internal audit division policies, etc. change daily. The constant change and lack of uniformity among the states produces unintended consequences. Even years later, after statutes or regulations have been in place and businesses have complied, states may choose to change the rules again (or sometimes they change their interpretation of the same rules without changing the rules). To complicate matters even worse, these changes may be imposed prospectively or retroactively; whichever has the least impact on the state's revenue. Consequently, taxpayers who have relied on the state's interpretation or challenged the state's interpretation, may owe additional tax or be unable to obtain refunds they deserve.
brian strahle, founder/managing member
In 2009, I read the book "Tribes" by Seth Godin. It was the spark that ignited my desire to start writing my state tax blog, "leverage salt." Today, the blog has over 900 posts on a variety of state tax topics. I have also written blogs for accountingweb.com and other sites.
I was interviewed by Bloomberg BNA in 2013 to provide my perspective on blogging, check it out: Expert Insight: Brian Strahle on Blogging, Creativity, and Coping with SALT Celebrity
In 2013, after working in public accounting firms and corporate tax departments for almost 20 years, 'leverage salt,' the blog, turned into "LEVERAGE SALT, LLC." My focus is state tax research and writing to make the 'game' easier.
All services are provided for any state and the following tax types: income tax, franchise tax, gross receipts tax, sales and use tax.
Fixed-fees and monthly retainer agreements available.
I work with tax departments as an independent contractor to help them do more with less, to fill the gap and help them complete a variety of projects. I provide them with a partner-level multistate tax resource not bound by audit-independence restrictions or bureaucracy.
accounting firms | law firms
I subcontract with accounting firms and law firms to help them provide state tax consulting services to their clients. Using my experience with both income tax and sales/use tax in almost every state, along with my personal network, I provide them with a partner-level multistate resource who is able to get a variety of projects done with minimal supervision and without incurring partner-level cost. I also provide National Tax Office and knowledge management services.
Benefits of National Tax Office Services include:
- Enrich the firm's position as a leader in the analysis of SALT technical developments by publicly displaying insights related to complex tax issues and key business decisions
- Enhance relationships with key state government officials and contacts in organizations such as COST, TEI, MTC, Tax Foundation, etc.
- Augment interaction with clients resulting in stronger relationships
- Boost cooperation and collaboration between firm tax professionals
- Assist firm tax professionals in achieving their goals by providing leverage
- Facilitate thought leadership opportunities for firm tax professionals
- Heighten the technical reputation of firm tax professionals in the marketplace
National Tax Office services may include:
- "Ghost Writing"
- Daily tweets
- Daily blog posts
- Weekly Alerts to clients
- Monthly Articles
- Practice Development
- Collaborating with practice / office leaders to discuss client issues / insights / perspectives
- Internal training / discussion leader
- External speaking engagements
- Subcontractor Services / Subscription Services
- Customized legislation, court case, issue monitoring / interpretation / application for specific firm clients
- Customized Technical Alerts for specific firm clients
- Audit protests
- Private Letter Rulings
- Technical Memos
- Help-Desk / calls / e-mails, confirmation of research, common questions
- Coalitions / Written comments on proposed legislation
I work with tax research publishers to write or review technical material to expand or build out their libraries and create useful tools for state tax professionals.
I currently serve as the subject matter expert for Bloomberg BNA's State Tax Analyzer product. I have served as an author for Thomson Reuter's Catalyst research product, and am currently writing and creating a state tax library for another publisher.
I collaborate with tax policy organizations (such as Council on State Taxation (COST), Tax Foundation, Multistate Associates Inc., Multistate Tax Commission, National Conference of State Tax Legislatures, Tax Executives Institute, Center on Budget and Policy Priorities, The Institute on Taxation and Economic Policy, Federation of Tax Administrators), on policy statements, studies, articles and reports to promote fair state tax policy and avoid unintended consequences.
During my career I have presented 50+ seminars or webinars to help clients build skill. Go here to view list.
experience with the following issues:
- Sourcing of Services
- Establishing the right to apportion
- Inclusion of gross proceeds v. net gain in sales factor
- Joyce v. Finnigan
- Throwback / Throwout rules
- Alternative apportionment (relief)
- Composition of Unitary business group
- Tax Base
- Tax Attributes
- Pass-Through Entities
- Entity v. Aggregate theory
- Unitary (tax base / factor flow-up) v. nonunitary (allocation)
- Sale of partnership interest
- Non-resident withholding compliance
- Composite return filing options
- Sourcing of guaranteed payments
- Single-Member LLC obligations and liability
- Multi-tiered entities (compliance and controversy)
- Sales and Use Tax
- Amazon / affiliate nexus
- Reporting requirements
- Situs of services
- Transactions with governmental entities
- Resale exemptions
- Bundled transactions (mixed-transactions)
- Cloud computing (SaaS)
- Software (custom v.canned)
- Construction contractors (prime contractor, subcontractor, real estate owner)
- Sale / leaseback transactions