LEVERAGE SALT helps clients avoid and resolve state tax controversy; builds tools for tax professionals; and positively influences state tax policy.
All services are provided for any state and the following tax types: income tax, franchise tax, gross receipts tax, sales and use tax.
900+ blog posts on a variety of state tax topics (blogging since 2009)
Brian was interviewed by Bloomberg BNA - see Bloomberg BNA's State Tax Blog - "Expert Insights: Blogging, Creativity and Coping with SALT Celebrity" (May 14, 2013)
strategic RESEARCH & controversy SERVICES
- Technical memos
- Sales taxability matrices
- Audit defense | Audit protests | Administrative Appeals
- Litigation support | subcontractor to law firms
- Letter ruling requests
- Pre-filing review
- Reverse audits | refund claims | amended returns
- Comments on proposed legislation
- Policy statements and studies
- Training materials
- Publisher libraries, portfolios
- Subject matter expert for software tool development
Fee Options: Fixed-fee per service or flat-fee per month for multiple services or 12-month contract for unlimited services.
LEVERAGE SALT 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.
Additionally, LEVERAGE SALT works with tax research publishers to write or review technical material to expand or build out their libraries, collaborates with tax policy organizations on policy statements, studies, articles, reports, comments and testimony, and partners with tax software companies to enhance or build new software tools for state tax compliance or planning.
LEVERAGE SALT uses it's experience and abilities to serve as a consultant to companies directly, and as a subcontractor to accounting and law firms.
LEVERAGE SALT has experience in almost every state, and also has a personal network of state tax professionals located throughout the country to call upon when additional resources are necessary.
sample PROJECTS INCLUDE:
- 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:
LEVERAGE SALT currently serves 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
SUBSCRIBE TO THE LS HELP-DESK
- Unlimited questions
Fee Options: Flat fee per month.
EXPERIENCE WITH THE FOLLOWING:
- 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
Subscribe to custom monitoring & Alerts
- By industry
- By state
- By tax type
- By issue
- Alerts may be provided daily, weekly or monthly
Fee Options: Flat fee per month.
Do you have information overload? State tax developments happen daily through legislation, court cases, rulings, etc. Some apply to your business and some don't. Let LEVERAGE SALT monitor those specific states, taxes and issues that are important to you so you don't have to. Receive customized alerts that apply to your business.
Brian has written 40+ articles throughout his career, including his column, "The SALT Effect" in Tax Analysts State Tax Notes.
Ghost-writing thought leadership
- Blog posts
- Articles / Whitepapers
Fee Options: Flat fee per piece or flat-fee per month or 12-month contract for unlimited pieces.
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 helps non-big 4 accounting firms meet this need by either supplementing or serving as their state tax national tax office. As a ‘ghost writer,’ LEVERAGE SALT writes alerts, articles, whitepapers, presentations and blog posts.