RESULTS

• While conducting a state income tax FIN 48 reserve analysis for a large middle-market company, identified over $1,000,000 in state income tax refund opportunities and $300,000 in prospective annual state income tax savings.  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.
• Performed a state income tax nexus look-back review for a middle-market company, and identified $350,000 in refund opportunities and $100,000 in prospective annual state income tax savings.
• Effectively represented and defended a corporation's position in regards to a Minnesota sales tax audit assessment (auditor assessed sales tax on what was perceived to be a "mixed-transaction" or "bundled transaction").  Prepared and filed written protest with the Minnesota appeals office resulting in the elimination of the entire $1,200,000 assessment.
• Obtained $500,000 reduction in Washington D.C. sales tax audit assessment by effectively representing a corporate taxpayer who received a jeopardy assessment (reviewed audit assessment and identified opportunities to reduce assessment, formulated audit defense game plan and taxpayer positions, gathered necessary documents, prepared written protest which presented the taxpayer’s position and information in an effective manner).
• Effectively represented and defended a Minnesota individual taxpayer in an income tax residency audit resulting in a $20,000 assessment; potential assessment was over $1 million.
• Successfully obtained apportionment relief by petitioning for apportionment relief with appeals after audit assessment was made. Reduced client's tax liability by 60%.
• Performed in-depth “Amazon.com” nexus analysis for e-commerce retailer and created and implemented a state and local tax risk management plan.
• Conducted research in eleven states for medical device manufacturer to determine sales and use tax taxability of device, and assisted in execution of plan to minimize exposure.
• Provided an analysis of a service company’s state and local tax compliance risk regarding the use of the Internet/client portal, (“cloud computing”) etc. to facilitate the delivery of their service.
• Structuring and tax planning saved real estate developer approximately $1,300,000 in B&O tax and $1,000,000 in sales tax on 9 projects in Washington.
• Obtained $3,000,000 in Florida Enterprise Zone Sales Tax Refunds for real estate developer on four development projects. Saved real estate developer approximately $140,000 in outside consultant fees.
• Reduced original state income tax and sales tax audit assessments from $2,000,000 to under $500,000.
• Performed reverse audits on all Arizona real estate sales, resulting in the filing of amended returns and refunds of approximately $1,000,000.
• Filed and monitored California LLC Fee refund claims of approximately $300,000.
• Developed restructuring/planning idea for S corporations and pass-through entities. Resulted in annual state tax savings of $500,000 for $200 million dollar manufacturing client based in Illinois.
• Identified and obtained a $700,000 refund for a $150 million dollar manufacturer based in Illinois by applying P.L. 86-272. Also resulted in annual state tax savings of $150,000.
• Reviewed several clients’ invoices and supporting documents to obtain almost $2,000,000 in refunds under the Illinois Manufacturer Purchase Credit.
• Successfully protested a Minnesota sales tax audit regarding canned vs. custom software resulting in tax savings of $75,000.
• Successfully defended a business vs. nonbusiness income position in appeal of a New Mexico income tax audit resulting in tax savings, and more importantly, providing support for the position being taken by the company in all states.
• Researched the new Texas Margin Tax (franchise tax) rules and developed an application plan for how a group of pass-through entities should file returns. Also presented planning options (structure changes) to minimize the tax impact.