Our State and Local Tax team is comprised of approximately 30 attorneys with experience in corporate income, sales/use, gross receipts, excise, property, payroll and many other taxes.
The breadth of our practice is notable for the types of services we provide our clients.
Consulting – we advise our clients on the tax consequences of their products, services, and transactions. Our advice has enabled them to determine the sales taxability of new offerings, the tax consequences of corporate reorganizations, and the identification of more efficient tax structures. Our work also includes advising our clients of the financial statement consequences of their tax positions.
Controversy – we represent our clients at every stage of tax disputes, from the receipt of audit letters, through trials, to appeals through state supreme courts. We approach controversies with the goal of identifying favorable resolutions. In those instances when matters cannot be resolved, we bring to bear extensive litigation and appellate experience. Our litigation has altered the SALT landscape and redefined how states and localities impose taxes.
Policy – many of our clients actively monitor state and local tax legislation and regulation. We provide monitoring services to our clients and alert them to proposals that may affect their businesses. We also provide our advice – including proposed legislative and regulatory language – to assist our clients to affect the adoption of particular provisions.
Our team is comprised of experienced SALT lawyers, several of whom have gained experience in Big 4 accounting firms and state tax organizations. We work collaboratively and bring the best team to each client challenge. Our SALT team is also known for its thought leadership. Our writing covers nearly every SALT development and is looked to by our clients and friends as a reliable source of SALT information and opinion.
Our lawyers are experienced in all aspects of SALT law. Our experience includes:
- representing a technology company before the California Court of Appeal in a matter related to the company’s characterization of its software sales for income tax purposes in California. The Court of Appeal reversed the trial court’s decision and upheld the company’s use of costs-of-performance sourcing
- representing one of the US’s largest wireless carriers in state sales tax matters, securing more than $40 million inrefunds for the client
- saving a Fortune 100 software and hardware company $70 million in potential tax liabilities stemming from a Washington State sales tax and Business& Occupation Tax dispute
- providing state tax advice and consulting to a leading online retailer on the taxability of their goods and services across the US
- serving as national state tax counsel to a Fortune 50 conglomerate and advises the company in every state in which it does business. We also provided state tax consulting and advice to the company and represent the company in its audits
"Eversheds Sutherland is a go-to firm for many legal issues, particularly state-level tax issues that require thoughtful analysis."
2024