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

  1. Developing and writing new California income tax and sales tax library (includes all sections, issues, topics)
  2. 50-state research project to update sections on "Consent to Be Taxed" related to composite returns and withholding for non-resident owners of partnerships
  3. 50-state research project to update sections on Net Operating Losses
  4. 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
  5. 23-state research project to add additional insights and commentary on related party expense add-back provisions
  6. 50-state research project to analyze and document each state's treatment of Interest Charge Domestic International Sales Corporations (IC-DISCs)
  7. 50-state research project to identify and explain each state's throwback and throwout rules
  8. 50-state research project to clarify whether each state follows Joyce or Finnigan rule
  9. 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
  10. 32-state research project to provide the technical details of each state's franchise tax regime
  11. 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):

  1. Separate / Combined / Consolidated filing methods
  2. Pre or Post Combination 
  3. Apportionment methods and formula
  4. Federal income tax deduction 
  5. State income tax deduction / addback
  6. Bonus depreciation adjustments
  7. Estimated payment safe-harbors
  8. Tax rates
  9. Minimum taxes
  10. Net Operating Loss tracking and utilization
  11. Foreign Source Dividends
  12. Royalties
  13. Industry apportionment formulas (manufacturing, retail, financial organizations, insurance, transportation, oil/gas, telecommunications, etc.
  14. Mixed-industry combined reporting
  15. Franchise Tax
  16. IRC Sec. 382 Limitations on NOLs

WRITING

In addition to writing 900+ blog posts, I have written 60+ articles (including ghost-writing) throughout my career, including my column, "The SALT Effect" in Tax Analysts State Tax NotesI have also ghost-written multiple articles for accounting firms which are NOT listed below.

I was interviewed by Bloomberg BNA - see Bloomberg BNA's State Tax Blog - "Expert Insights:  Blogging, Creativity and Coping with SALT Celebrity" (May 14, 2013)

ARTICLES IN TAX ANALYSTS STATE TAX NOTES

SAMPLE ARTICLES: COPYRIGHT TAX ANALYSTS. REPRINTED WITH PERMISSION. 

LIST OF ALL TAX ANALYSTS ARTICLES

  1. "Indiana Manipulates Income-Producing Activity Into Market-Based Sourcing" (March 23, 2015)
  2. "Cloud Computing, Practically Speaking" (January 26, 2015)
  3. "Maryland: Who Needs Combined Reporting When You Have Gore?" (March 10, 2014)
  4. "Credits and Incentives Are Inevitable - Unless?" (March 3, 2014)
  5. "Critical Factors To Deducting Foreign Income in Virginia" (February 24, 2014)
  6. "The Bridge to 'Nowhere Income'" (February 17, 2014)
  7. "Is P.L. 86-272 Unconstitutional?" (February 10, 2014) 
  8. "Texas Court Finds Comptroller's Position Inconsistent With Statutory Language" (February 3, 2014)
  9. "Professional Employer Organizations Are A Double-Edged Sword" (January 27, 2014)
  10. "The Next Big Thing Is Here" (January 20, 2014)
  11. "Time to Make The Donuts" (January 13, 2014)
  12. "The Tightrope of Acceptable Intercompany Transactions" (January 6, 2014)
  13. "Credits and Incentives Are Inevitable - Accept It" (December 23, 2013)
  14. "Flawed Regulations, Audit Mistakes Lead to Taxpayer Victory in Hartney" (December 16, 2013)
  15. "Reshoring Should Inspire Favorable State Tax Policy" (December 9, 2013)
  16. "What Level of Tax Avoidance is Acceptable?" (December 2, 2013)
  17. "Tax Havens Pushing States to Worldwide Combined Reporting?" (November 25, 2013)
  18. "Grass-Roots Arguments for Transparency Are Misguided" (November 18, 2013)
  19. "UDITPA Rewrite Necessary, but Will States Listen?" (November 11, 2013)
  20. "Market-Based Sourcing Goes Incognito" (November 4, 2013)
  21. "Not All Intercompany Transactions Are Created Equal" (October 28, 2013)
  22. "Ignorance May Not Be Bliss When It Comes to 'Zappers'" (October 21, 2013)
  23. "Top Secret: How to Apply D.C. Combined Reporting to Unincorporated Businesses" (October 14, 2013)
  24. "In Search of a Win-Win for the Virginia BPOL Tax" (October 7, 2013)
  25. "Life After Equifax:  Offense or Defense" (September 30, 2013)
  26. "The Struggle for Clarity" (September 23, 2013)

INTERVIEWS

  1. Bloomberg BNA's State Tax Blog - "Expert Insights:  Blogging, Creativity and Coping with SALT Celebrity" (May 14, 2013)
  2. Quoted by Tax Analysts in State Tax Today article entitled, "Single Sales Factor May Open Up Planning Opportunities in Virginia" (April 2012)
  3. Quoted by Tax Analysts in Practice Notes article entitled, "Using Market-Based Sourcing For Service Receipts:  The Difficulties" (May 2010) 
  4. Interviewed for article on federal taxation of leasing for RSM’sAdvantage (2004)
  5. Interviewed by Springfield Business Journal regarding tax law changes for 2002 and 2003 tax seasons (2002) 

OTHER ARTICLES

  1. Leaping the Hurdles to Track State Net Operating Losses (NOLs) (BBNA Software Insights Article; 2016)
  2. UNICAP inventory controversy issues for Tax Adviser (2006)
  3. “Tax Inventory Strategies to Improve Cash Flow” for RSM’s Advantage (2005)
  4. Business Developer Guide on Tax Inventory Services for RSM tax professionals (2005) 
  5. RSM’s 2004 and 2005 Tax Drive campaigns (2004 and 2005)
  6. Incurred But Not Reported (IBNR) Medical Claims for RSM’s HR Update (2004)
  7. Breaking News Alert on the American Jobs Creation Act of 2004 for RSM’s Tax Planning Guide (2004)
  8. “IRS Formal Guidance on Tax-Exempt Orgs Joint Venture with For-Profit Partners” for RSM’s MEDNews (2004)
  9. Federal law changes related to prepaid expenses and 12-month rule for Springfield Chamber of Commerce (2003)
  10. Illinois law changes related to Illinois Manufacturers Purchase Credit (MPC) for Illinois Association of Aggregate Producers (IAAP) (2003)
  11. “Relying on IRS’ Advice” for Springfield Chamber of Commerce (2002) 
  12. Illinois Manufacturers Purchase Credit (MPC) for the IAAP (2002) 
  13. “State Taxes Require Proactive Approach” for Illinois Manufacturing Association (2002)

TEACHING

The following is a list of the training I have delivered throughout my career (50+ presentations).

WEBINARS

  • Bloomberg BNA State Tax Planning Webinar Series: "Strategic Planning Around State NOLs" (4 of 4) (April 20, 2017)
  • Bloomberg BNA State Tax Planning Webinar Series: "State Tax Planning for M&A and Entity Changes (3 of 4) (March 23, 2017)
  • Bloomberg BNA State Tax Planning Webinar Series: "Related Party Transactions" (2 of 4) (February 16, 2017)
  • Bloomberg BNA State Tax Planning Webinar Series: "Unitary/Combined vs. Separate Reporting" (1 of 4) (January 19, 2017)
  • "Clearing State NOL Hurdles: Identifying Pitfalls and Minimizing Risks" (Bloomberg BNA) (March 22, 2016) 
  • "State and Local Tax Challenges with Leases of Equipment and Other Assets" (Strafford Publications) (June 27, 2013)
  • "State Taxation of Pass-Through Entities" for Baker Tilly Virchow Krause, LLP's Monday Night Tax Call (June 3, 2013)
  • "State and Local Tax Trends" during Baker Tilly Virchow Krause, LLP's Business Year-End Tax (December 6, 2012)
  • "State of Confusion: Sales and Use Tax in an Electronic World" (April 2010)
  • "FIN 48:  State Income Tax Issues" to Baker Tilly Virchow Krause, LLP firmwide tax practice (November 2009)
  • "Tax Inventory Methods" to RSM McGladrey (RSM) network firm members (2006)
  • "Accounting Methods Update" with Les Schneider, Nationally Recognized “Guru” (2006)
  • “Better Cash Flow: Turning Good Business Decisions into Great Tax Strategies” (2005)
  • Developed and presented the following to RSM tax professionals and RSM network firm members annually (2004, 2005, and 2006):
    • Accounting Methods: Revenue Recognition
    • Accounting Methods: Deductions and Economic Performance
    • Personal Property Like-Kind Exchange Program
    • Auto Dealer Trade Discounts and Advertising Credits
    • Basics of Inventory
    • UNICAP (263A) Inventory Capitalization
    • LIFO (Last-in, First-Out) Inventory Method
    • IPIC (Inventory Price Index Computation) LIFO Inventory Method
    • Considering LIFO Adoption

SEMINARS

  • "D.C. Combined Reporting:  In Search of Clarity" at Greater Washington Society of CPAs Tax Section Meeting (July 17, 2013)
  • "D.C. Combined Reporting" at Baker Tilly Virchow Krause, LLP's CFO Roundtable in D.C. office (January 23, 2013)
  • "State Income Tax Update" at Baker Tilly Virchow Krause, LLP's Annual Tax Conference in Milwaukee (November, 2012)
  • "State Income Tax Provisions:  Issues and Opportunities" at Ernst & Young, LLP Accounting for Income Taxes Annual Update in Richmond, Virginia (September 19, 2012)
  • "State Income and Franchise Tax Update" at Ernst & Young, LLP's State and Local Tax Annual Update in Norfolk, Virginia (May 24, 2012)
  • "State Income and Franchise Tax Update" at Ernst & Young, LLP's State and Local Tax Annual Update in Richmond, Virginia (May 23, 2012)
  • "Indirect Tax, State and Local Tax Update" at Ernst & Young, LLP's Hampton Roads Tax Executive Workshop in Norfolk, Virginia (February 2012)
  • "Indirect Tax, State and Local Tax Update" at Ernst & Young, LLP's Hampton Roads Tax Executive Workshop in Norfolk, Virginia (October 2011)
  • "State Income Tax Update" at Ernst & Young, LLP's Seventh Annual "Update on ASC 740, Accounting for Income Taxes" in Richmond, Virginia (September 2011)
  • "National State and Local Tax Update" to Baker Tilly Virchow Krause, LLP firmwide tax partners and managers (December 2010)
  • "The Nexus Wars:  Fighting in an Ever-Changing Landscape" at the Minnesota CPA Society Annual Tax Conference in Minneapolis (November 2010) 
  • State and Local Tax Practice "lunch-n-learn" presentation to Baker Tilly Virchow Krause, LLP's Minneapolis office (August 2010)
  • "Sales Taxation of Leasing Transactions" at Interstate Tax Corporation’s Advanced Sales and Use Tax seminar in Miami, FL (May 2010)
  • Minnesota's New "Angel Investment Credit" at Baker Tilly Virchow Krause, LLP's "Life Sciences Executive Forum" (May 2010)
  • National State and Local Tax Update to Baker Tilly Virchow Krause, LLP firmwide tax partners and managers (January 2010)
  • "Accounting Methods and Inventory" - RSM tax professionals (2006)
  • "Accounting Methods and Inventory" - RSM Partners at 2006 MD Tax Symposium (2006)