Dow Lohnes and its affiliate, Dow Lohnes Price Tax Consulting Group LLC, provide a wide array of state and local tax consulting services for corporations, partnerships, limited liability companies and other businesses. Our work in this area includes representing clients in connection with state tax controversy matters, state and local tax planning, business transactions, voluntary disclosures and private rulings, and tax legislation matters. All of our state tax professionals have extensive public and private service backgrounds and thus are sensitive to and cognizant of the various tax issues confronting our clients.
State and Local Tax Controversy
The state tax controversy work of Dow Lohnes and its affiliate encompasses income tax, sales and use tax, property tax, and other types of state and local taxes. We handle all phases of state tax controversy matters from the beginning of an audit, through the fieldwork, the preparation and filing of a protest, to the administrative appeal or hearing stage of a proceeding. We also work to identify potential affirmative claims that our clients may be able to pursue with respect to prior tax years, and we analyze the impact of audit issues and their possible settlement on our clients in future tax years. Dow Lohnes professionals also work with clients who choose to pursue further appeals to state-level administrative or judicial courts.
State and Local Tax Planning
Dow Lohnes’ state tax professionals regularly assist clients in reviewing their operations, business holdings and organizational structure to identify and implement possible state and local tax planning opportunities. We review and analyze clients’ tax return filing posture to identify possible alternative filing strategies; evaluate the division of income and sales among different jurisdictions; analyze state income tax sourcing and the classification of income as business or nonbusiness; and determine whether opportunities exist for restructuring or other state tax planning, while considering related state tax exposure as well as practical business concerns. We also work with our clients in the planning and restructuring of their business holdings (including through mergers, acquisitions and dispositions), and we answer a wide variety of state tax questions that arise from day-to-day business.
State and Local Tax Considerations in Transactions
Our state tax professionals are experts at reviewing and analyzing a wide variety of state tax issues relating to mergers, acquisitions, dispositions, tax-free exchanges and other business transactions for potential state and local tax issues and possible tax planning opportunities. This work encompasses an analysis of the income tax, sales and use tax, and transfer tax issues presented by a proposed transaction, as well as other tax-related issues, such as successor tax liability, and bulk sale notification requirements. We also review and comment on the state tax and related provisions of the operative transaction documents, and we perform tax due diligence in connection with potential acquisitions, including identifying potential state tax exposures and recommending tax saving strategies.
State Tax Voluntary Disclosures and Rulings
Dow Lohnes state tax professionals assist clients in the negotiation of state and local tax settlements involving the voluntary disclosure of tax liability (income tax, sales and use tax, unclaimed property tax, etc.). This work involves our thorough review and quantification of a client’s potential tax liability and, when appropriate, anonymous inquiries to a state or local taxing authority to secure a final settlement. Where the relevant state tax law may be uncertain, Dow Lohnes professionals also secure private tax rulings for clients to assure them that they will receive the desired state tax treatment or to clarify a state’s tax position on a particular issue. In appropriate circumstances, we may be able to secure a favorable ruling for a client on an anonymous basis.
State Tax Legislation
Dow Lohnes professionals work with clients to pursue favorable state tax legislation and regulatory guidance.