TURNING THE TECHNICAL INTO THE PRACTICAL
LEVERAGE SALT, LLC (LS) is a state tax research and writing firm focused on helping your business or your clients turn the technical into practical solutions.
LS daily researches complex, non-uniform multi-jurisdictional tax law and developments that impact every business' ability to function and operate. LS helps companies operating in multiple states, comply, mitigate risk, and defend positions under audit.
LS specializes in analyzing, interpreting and applying court cases, rulings, proposed and current legislation to multifaceted fact patterns in a variety of industries across all states. The research may be related to developing support for return filing positions, defending positions under audit, identifying refund opportunities or mitigating risk. The result of the research is customized to the client situation and may be a written memo, audit protest, taxability matrix, refund request, private letter ruling, etc.
LS works with corporate tax departments, accounting firms, and law firms either on a project basis, as a subcontractor, or co-sourcing arrangement. LS also works with middle market companies and smaller firms that do not have in-house state tax expertise.
LS also provides accounting and law firms with national tax office services and/or ghost-writing of thought leadership. Meaning, LS provides technical analysis of changing state tax laws, draft and edit alerts designed for external distribution, provide in-depth analysis of key issues, support for internal and external training programs, and conduct research and drafts memorandums for clients.
Additionally, LS works with tax research publishers to write or review technical material to expand or build out their libraries, collaborate with tax policy organizations on policy statements, studies, articles, reports, comments and testimony, and partner with tax software companies to enhance or build new software tools for state tax compliance or planning.
Some unique services (described below) include:
- State Tax Controversy & Risk Management Help-Desk
- Custom Monitoring Service (Your LEVERAGE SALT REPORT)
- Ghost-Writing (Articles, Blog Posts for Accounting and Law Firms)
All services are provided for any state and the following tax types: income tax, franchise tax, gross receipts tax, sales and use tax.
state tax controversy & risk management help-desk
Outsource all of your state tax research to LEVERAGE SALT.
Any question, any tax type, any state, any time.
- No longer have to stop what you are doing to do a deep dive into tax research or an issue you are unfamiliar with.
- No longer be forced to file a return without getting an answer simply because you and your team don't have time.
- Don't DIY your research to get a general answer and still be confused as to whether your conclusion is correct. Talk to a live person with 20+ years experience. Discuss your facts and what you think the answer is.
What You Get:
- Specific answer.
- Copy of applicable authority (i.e., statute, regulations, case, ruling, etc.)
- If answer is unclear, you will get possible answers based on authority and facts; along with suggestions for changes in facts to get clearer answer
Provided on a fixed-fee basis (monthly or annual).
Custom Monitoring service (your leverage salt report)
Let's face it - there is too much noise in the world. Too much information. Too many opinions. Too much advice and fear. In the state tax world, things change daily and the research publishers and Big 4 are great at telling us all of it. Unfortunately, you don't need to know 'all of it,' and you definitely don't have time to read 'all of it.' You need to know what you need to know and that's it. You may not know exactly what you need to know, but you most likely know what states, tax types and issues you need to monitor. That is why LS provides a custom monitoring service.
You pick the states, the tax types and the topics you want to know about it. For example, you may want to monitor California, New York and Texas for any developments related to income tax and sales tax. You could stop there or you could make it even more granular by saying you only want to know sales tax developments related to a specific industry like software/technology or construction real/estate, manufacturing, retail, trucking, etc. You could also break it down by topic like nexus, apportionment, sales tax exemptions, sales tax of a specific item, etc.
Bottom line - go as broad or narrow as you want. Don't pay for information you don't need or don't read.
What You Get:
- Custom weekly report that only includes the states, tax types and topics you want to know about.
Provided on a fixed-fee basis (monthly or annual).
GHOST-WRITING (articles, blog posts for accounting and law firms)
The marketing departments of accounting firms are always looking for more content to promote the firm. More alerts, articles, whitepapers, etc. The problem is that firm professionals are so busy with client work that they don’t have time to dedicate to thought leadership. Yet, partners and clients are looking for alerts and tips from their accounting firms when developments happen. The Big 4 accounting firms are able to produce large volumes of timely developments because of their dedicated resources. Consequently, LEVERAGE SALT also helps non-big 4 accounting firms meet this need by ‘ghost-writing’ strategic thought leadership.
Fixed Fee (per article or annual):
- $2,000 per article
- 12 articles (one each month - price drops to $1,500 per article) - total fee = $18,000
- 24 articles (two each month - price drops to $1,000 per article) - total fee = $24,000
SAMPLE CLIENT RESULTS
- Obtained $550,000 sales tax refund related to client's intercompany management fee involving several different types of services in Pennsylvania
- Provided practical insight to client as to what positions they should take regarding the sales taxation of cloud computing by conducting 40-state research project and preparing custom matrix
- Technical support for client's creation/implementation of a custom sales ‘tax and fee’ engine (40 states)
- Multi-year review and analysis of client's sales tax exemption review process (20 states) to determine best practices and provide recommendations whether the client should continue, change or eliminate the current process
- Identified over $1,000,000 in state income tax refund opportunities and $300,000 in prospective annual state income tax savings while conducting a state income tax FIN 48 reserve analysis for a large middle-market company. These refund opportunities were identified in conjunction with the opportunity to utilize Voluntary Disclosure Agreements (VDAs) in multiple states to not only minimize the company's state income tax liability, but also reduce or eliminate the state income tax FIN 48 reserve.
- Identified $350,000 in refund opportunities and $100,000 in prospective annual state income tax savings while performing a state income tax nexus look-back review for a middle-market company.
- Eliminated $1,200,000 sales tax audit assessment by preparing and filing a written protest with the Minnesota appeals office regarding a "mixed-transaction" or "bundled transaction.”
- Obtained $500,000 reduction in sales tax audit assessment after client received a jeopardy assessment from Washington D.C.
- Reduced $1 million individual income tax assessment to $20,000 for an individual taxpayer in a Minnesota income tax residency audit
- Reduced client's income tax liability by 60% by petitioning and obtaining apportionment relief with Minnesota appeals after audit assessment
- Mitigated risk and improved compliance for medical device manufacturer operating in 11 states by researching and providing guidance regarding the sales and use tax taxability of the company’s device
- Provided peace of mind to company regarding the sales tax consequences of its Internet/client portal, (“cloud computing”) etc. used to facilitate the delivery of their service
- Eliminated $1,300,000 in Washington B&O tax and $1,000,000 in sales tax on 9 real estate projects
- Obtained $3,000,000 in Florida Enterprise Zone sales tax refunds on 4 real estate projects
- Obtained $1,000,000 in Arizona Transaction Privilege Tax refunds after performing reverse audits on Arizona real estate sales
- Obtained $300,000 in California LLC Fee refunds
- Reduced annual state income taxes by $500,000 for a $200 million Illinois manufacturer by developing restructuring plan for S corporations and pass-through entities
- Identified and obtained a $700,000 refund and annual state tax savings of $150,000 for a $150 million Illinois manufacturer by applying P.L. 86-272
- Reduced sales tax audit assessment by $75,000 related to ‘canned vs. custom software’ in Minnesota
SAMPLE RESEARCH PROJECTS
- Developing and writing new California income tax and sales tax library (includes all sections, issues, topics)
- 50-state research project to update sections on "Consent to Be Taxed" related to composite returns and withholding for non-resident owners of partnerships
- 50-state research project to update sections on Net Operating Losses
- 50-state research project to provide additional clarification and analysis regarding the sourcing of services and intangible property; specifically, the application of market-based sourcing, and utilization of market sourcing methodology within costs-of-performance statutes and regulations
- 23-state research project to add additional insights and commentary on related party expense add-back provisions
- 50-state research project to analyze and document each state's treatment of Interest Charge Domestic International Sales Corporations (IC-DISCs)
- 50-state research project to identify and explain each state's throwback and throwout rules
- 50-state research project to clarify whether each state follows Joyce or Finnigan rule
- 50-state research project to provide technical instruction on each state's law regarding the taxpayer's ability to request, and the state's ability to impose, alternative apportionment
- 32-state research project to provide the technical details of each state's franchise tax regime
- 49-state plus NYC research project regarding each state's conformity with the Internal Revenue Code as it relates to mergers and acquisitions, changes in ownership, etc.
SUBJECT MATTER EXPERT
I currently serve as a subject matter expert for Bloomberg BNA Software's new state income tax modeling tool (BNA State Tax Analyzer) by performing research, providing state-by-state tax rules and technical review, comments, and suggestions for improvements. The project involves 50-state research to provide tax law support and guidance regarding the following for multiple tax years (1998 to current):
- Separate / Combined / Consolidated filing methods
- Pre or Post Combination
- Apportionment methods and formula
- Federal income tax deduction
- State income tax deduction / addback
- Bonus depreciation adjustments
- Estimated payment safe-harbors
- Tax rates
- Minimum taxes
- Net Operating Loss tracking and utilization
- Foreign Source Dividends
- Industry apportionment formulas (manufacturing, retail, financial organizations, insurance, transportation, oil/gas, telecommunications, etc.
- Mixed-industry combined reporting
- Franchise Tax
- IRC Sec. 382 Limitations on NOLs
For more information, check-out my other pages.