External consultants should not act like the hero.

They should help tax departments be the hero.


I often have lunch meetings with leaders and other tax professionals working within corporate tax departments. After one such meeting, it struck me as to the many challenges tax departments face. 


  1. Finding the right people (level of experience, personality, culture fit)
  2. Knowing how many people the tax department needs to provide value
  3. Justifying and getting approval for how many people the tax department needs
  4. Determining how to structure the tax department (by tax type, by company, by some other mix)
  5. Getting buy-in from other company departments to obtain information at the right time, and complete special projects to provide value (i.e., implementing smart ideas that reduce taxes without creating a high level of controversy risk, and positively impacting other business functions (i.e., finding ideas that align with business objectives))
  6. Outlining and determining the best process for compliance, audits, provision and planning functions
  7. Implementing and utilizing the right-fit software and technology solutions
  8. Managing external consultants and determining which ideas to use and which ideas to ignore
  9. Not getting stuck in the 'analysis paralysis' zone
  10. Not 'dying by meeting'
  11. Doing more with less

 These are just a few of the challenges. I know there are more. Tell me yours. Send me an e-mail at strahle@leveragesalt.com.


As a tax professional in a corporate tax department, you have to continually juggle priorities while meeting deadlines. Compliance and provision are never-ending tasks. Then add-in business changes and the lack of uniformity of state tax laws (that continually change as well), and you are faced with what can seem like you are walking up-hill to school (barefoot) both ways in the snow, everyday. Not to mention, having to conduct due diligence and planning for mergers and acquisitions, and managing and defending your company's uncertain tax positions during audits. The 'fire-drills' can be overwhelming to say the least. In the midst of these challenges, lowering your company's state effective tax rate and mitigating risk must remain top priorities, and become part of your day-to-day.


My goal is to make your tax department look good, and help the company thrive.

IT'S NOT ABOUT ME. I'm not here to tell you how smart I am. I'm here to help you be the hero. I want to know your situation, your facts, and then utilize my experience and connections to achieve your objectives.

I serve as an alternative to the Big-4 firms by providing your tax department with an independent partner-level resource that can do a multitude of tasks without supervision and disruption to you and your team. I seek to be a true partner and teammate.

My focus via LEVERAGE SALT, LLC is providing state income tax consulting services to Fortune 1000 companies or corporate tax departments. I help tax departments with state income tax provision, compliance, planning and controversy. 


  • ASC 740 (uncertain state tax positions analysis and review)
  • Current-Year Return Review (prior to filing)
  • Prior-Year Return Review (Reverse Audits)
  • Income Tax Filing Method Review (Separate, Combined, Consolidated, Unitary)
  • Income Tax Sourcing/Apportionment Review
    • Sourcing of Services (Market-Based Sourcing / Cost-of-Performance)
    • Establishing the right to apportion
    • Inclusion of gross proceeds v. net gain in sales factor
    • Joyce v. Finnigan
    • Throwback / Throwout rules
    • Alternative apportionment (relief)
  • Income Tax Base Review
    • Federal IRC Conformity
    • Related Party Addbacks
    • Transfer Pricing (intercompany transactions)
    • Foreign Source Income
    • Business v. Nonbusiness Income
    • Depreciation
    • Dividends Received Deduction
    • State-Specific Additions/Subtractions
  • Pass-Through Entities Review
    • 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)
  • Net Operating Loss Management / Preservation / Utilization / IRC Sec. 382 Studies
  • Due Diligence (Mergers & Acquisitions / Asset Sales / Stock Sales)
  • Restructuring / Modeling / What-if Scenarios
  • Audit Defense / Administrative Appeals 
  • RAR Compliance
  • Co-Sourcing / Outsourcing
  • Credits & Incentives Review


1. Search the LS Site. 

I have written more than 1,000+ blog posts on this site and at www.leveragestateandlocaltax.com. Chances are, I may have touched on your topic or issue at some point. Disclaimer, please use this site as a "high-level" guide or introduction to some of the issues your business or clients are facing. An experienced state tax professional should be consulted to obtain a conclusion regarding your specific situation and state(s) involved. Your answer will depend on the state and the facts.

2. Subscribe to Blog updates. 

I currently publish blog posts several times month. I write unique insights and commentary on multistate taxation and the state tax profession. By subscribing, you’ll get my latest thinking delivered straight to your inbox.

3. Utilize the LS Help-Desk / 2nd Opinion.

This is for those times when you don’t have a big state tax research project. Sometimes you just have a state tax question that you would love to bounce off a state tax professional without having to go through the time consuming engagement letter process, especially if you need an answer quickly (flat-fee per question or monthly flat-fee for unlimited questions).

4. Hire LS for your project.

If you have a specific project, let’s discuss your facts and determine the proper course of action. We will have a formal engagement letter that lines out the parameters of our agreement along with the fee and payment arrangements.

5. Hire LS on retainer.

If you are not sure how often you will need help, but want to have me on-call, you can hire me on retainer by paying a monthly fixed-fee. Retainer agreements must be a minimum of three months.