SALT Tax Controversy

Many businesses may find themselves under audit or in litigation because of the increase in state and local government audit activity. States and localities are becoming more sophisticated in identifying audit leads (both registered taxpayers and unregistered businesses), so the chances of being audited increase every year. Our experience shows that government auditors are also taking more aggressive positions, which can lead to more difficult audits and even to litigation.

At ZHF, our professionals work diligently to resolve controversies at the earliest stage possible to minimize the time and resources necessary to defend you at the audit level. If litigation is required, our attorneys have the necessary experience to represent you at all levels of administrative and judicial review.

We minimize the impact of audits and litigation by: (1) using our extensive knowledge and experience including past governmental experience to work closely with tax officials to reduce assessments during and after an audit; (2) reviewing compliance to determine if overpayments have occurred and using them to offset the results of the audit; (3) analyzing the litigation risks to prudently navigate assessments through all levels of appeal; and (4) using our negotiation experience throughout the audit and litigation process to resolve issues as quickly and favorably as possible.

To further discuss our Tax Controversy services and their benefits, please contact any one of the ZHF professionals.

Managed or Participatory Audits

ZHF may be able to perform the audit instead of or in conjunction with a government auditor in states that allow managed or participatory audits. Typically, managed or participatory audits can be performed if you proactively approach the government or if you have just received a notice for audit. Managed or participatory audits provide excellent value for businesses whether they are regularly audited or have never been audited. Generally, benefits of managed or participatory audits include (1) penalty waiver, (2) significant interest waiver, (3) control of the audit process, (4) better education of the audit and refund issues for client personnel.

As with our normal audit defense services, clients completing a managed or participatory audit can also take advantage of a Refund Checkup to determine if there are any overpayments that can be used to offset the results of the audit. Click the following link to see a detailed explanation of our Refund Checkup process.

Managed or participatory audits can typically be completed for the following tax types: sales, use, and gross receipts.

High Net-Worth Individuals

States and localities are aggressively pursuing personal income tax for individuals who have earned income (for example, deferred compensation or stock options) in a specific jurisdiction but have since attempted to change state residency to avoid paying personal income tax on those earnings once they are received or exercised. Our professionals can assist you with defending your tax positions and change of domicile on audit and our attorneys can assist you with litigation (if necessary) of assessments if the jurisdiction is unwilling to settle the issue(s).