State and Local Tax Controversy Services

State audits have been on the rise as states seek to boost declining revenues. Businesses now consider state and local tax compliance an area for possible risk as state and local controversy issues from audits are increasingly more and more relevant to overall business strategy. Be certain your tax positions and calculations can be defended if audited and your tax posture is consistent with your company’s overall operational goals.

However, once you become the focus of a state audit, or if you are concerned about future audits, you need tax professionals who have deep experience with the state departments of revenue.  You need specialists who know the state protocols and are ready to help you negotiate a solution where you meet your fiduciary obligations without creating risk for your business.

Hall & Company state and local tax specialists provide comprehensive support to businesses seeking state and local tax controversy assistance related to:

  • State income / Franchise tax audits
  • Gross receipts audits
  • Sales / Use tax audits 

Our state and local controversy services are designed to help you understand your compliance risk and negotiate with auditors using a well-structured approach. Our controversy services include:

Audit defense

We will work with you through all levels of the administrative process—from the beginning of audit field work through the administrative and appeals processes. Our specialists conduct a comprehensive review of your current audit positions and serve as your advocate in the state tax administration and appeal processes. We apprise you of your options to accept, protest or to settle the state’s adjustments or refund issues. 

Voluntary disclosure agreements

On a state by state basis we will determine your nexus footprint that identifies outstanding tax exposure for prior years and assist you through the “no name” amnesty or voluntary disclosure process to help mitigate past tax liabilities. 

Ruling requests and opinion letters

Hall & Co state and local specialists are available to develop persuasive ruling and opinion letters on complex laws and tax positions that apply to your specific facts.

Reverse audit process

If you have an impending audit or in the mists of a current audit, our state and local specialists may be able to identify and help recover potential refunds and overpayments, which may be used you to offset any potential audit assessments and accrued interest.

Pre-audit review

In a pre-audit our specialists perform a comprehensive analysis of exposure areas and make recommendations to mitigate and steer away from the exposure areas. We may also suggest alternate positions and other statistical sampling techniques.   

Reporting federal audit adjustments

State reporting requirements for a federal revenue agent’s report (“RAR”) can be time-consuming due to a company’s number of state filings and the required time frame for which to timely report the RAR.  Moreover, not all federal adjustments may apply to a state’s calculation of taxable income. Federal depreciation, federal credits and net operating loss carryover are among the adjustments that certain states do not conform to.  Our specialists help you prepare the proper documentation and identify the most cost-effective reporting for amended state tax return filings.

Tax risk management

Financial and taxing agencies are increasing taxpayer oversight. As such, the issue of tax risk is a growing concern. These specialists are able to negotiate complex regulatory issues in order to provide timely and responsive solutions.  This may include a nexus analysis, risk assessment, advisory opinions and voluntary disclosure initiatives.

Settlement process

Many states have tax settlement bureaus to settle civil tax matters in various stages of the administrative process rather than formally seek judicial remedies. Our specialists have vast settlement experience in preparing the necessary filings, documents and representations to secure a settlement agreement. 

Offers in compromise

If you have an outstanding tax liability that you are unable to pay, our specialists will team up with your legal counsel and the appropriate tax authorities to strike a compromise solution.

Payment and collection issues

Do you know that Hall & Company state and local specialists can help structure tax payment and collection structures with the appropriate taxing authorities? We can also assist with the release and stay of tax liens, orders to withhold and other collection enforcement issues.

Managed or certified audits

Our specialists are available to help you minimize tax audit interaction through state-managed or certified audit programs, where appropriate.  We focus on the limitation of penalties and interest and manage the process of managed or certified audits.