ReedSmith State Tax Practice Exceptional Experience For more information about our group, please visit www.reedsmith.com/state Reed Smith’s State Tax Practice has more professionals exclusively focused on state tax tax/ or contact: issues than any other U.S. law firm. Devoted to the full range of state tax matters, we do more than address individual issues as they arise. Our emphasis is on building strong client Lee A. Zoeller, Partner relationships, so we work to create comprehensive solutions that enable our clients to focus Practice Group Leader +1 215 851 8850 on moving ahead. This has resulted in our representation of more than 10 percent of the lzoeller@reedsmith.com Fortune 500 companies in state tax matters, and recognition by tax and business organizations, including The Wall Street Journal . Reed Smith Offices: Reed Smith’s state tax lawyers serve clients by leveraging a national platform with deep tax technical and industry experience. Our lawyers have diverse backgrounds, allowing us to Abu Dhabi understand more about our clients and their needs, and not solely the laws impacting them. Athens This depth and breadth of knowledge impacts how we address client issues – balancing the Beijing law against the economic, business, and social environments in which our clients work every Century City day. Chicago Dubai Scope of Services Frankfurt Hong Kong Our services include not only traditional legal services of audit defense and appeals – litigating Houston from the earliest of administrative levels all the way through to the United States Supreme Kazakhstan Court – but also nearly all areas of tax consulting. London Los Angeles Controversy & Litigation. Our controversy and litigation work encompasses all states and Munich all taxes, with particular emphasis in income/franchise tax, sales/use tax, real/personal New York property tax, and gross receipts taxes, such as the Texas Margins Tax and Washington B&O, Paris and Unclaimed Property. We assist clients with state tax controversies at the audit level, and Philadelphia represent clients at all administrative levels, federal and state courts, including the United Pittsburgh States Supreme Court. Because we understand that it is more cost effective for clients to Princeton conclude a matter as early as possible in the controversy process, we work diligently to Richmond achieve favorable settlement. As needed, we will defend clients through all judicial levels until San Francisco our clients’ goals are met. Representative matters are listed at the end and highlighted Shanghai throughout this brochure. Silicon Valley Tax Consulting. Our consulting work mirrors the subject-matter experience of our Singapore controversy and litigation work. Our ability to deliver consulting work differentiates our services Tysons from many other law firms. Our services include: Washington, D.C. Wilmington Performing multistate tax refund reviews Modeling multistate impact of changing tax laws and business facts r e e d s m i t h . c o m State Tax 2017
ReedSmith State Tax Practice Developing and implementing state tax minimization strategies for transactional Success Stories activity or general tax liabilities Rare Victories for Conducting and documenting FIN 48 reviews Intangible Holding Monitoring and advocating legislative, regulatory and other legal developments Company Structures: Prevailed in resolving Drafting legislation and regulations numerous cases involving Identifying, negotiating and implementing credits and incentives the intangible holding Developing unclaimed property reporting positions company of a major Developing compliance programs nationwide retailer and entities. Similarly helped Executing voluntary disclosure initiatives several clients facing tax Obtaining ad valorem tax exemptions, including through appeal exposures of tens of Assisting with public relations issues resulting from tax matters millions of dollars in New Jersey in a dispute involving intangible holding Recognized Leaders and Diverse Perspectives companies. Because we remain on the cutting edge of developments and changes in state tax, we are Record Settlements for regularly recognized by legal and business communities, hold leadership positions in leading Industry and Individuals: state tax organizations, and are sought out to speak at local and national tax seminars and Obtained the largest conferences. income tax refund settlement for a bank Legal/Business Recognitions. Our experience has been highlighted by Legal 500 , The taxpayer; large settlements Wall Street Journal , Forbes , NetworkWorld, E-Commerce Times, The Hartford Courant , State for a pharmaceutical Tax Notes and BusinessWeek . company in Illinois; some of the largest oil and gas Leadership Positions. We serve in leadership positions for the Institute for Professionals company cases to come in Taxation, Taxpayers’ Federation of Illinois, the State Income Tax Monitor, and the Journal before the California of Multistate Taxation . Franchise Tax Board; and helped settle the largest Speaking Engagements. Our attorneys are regularly invited speakers at national and personal income tax regional conferences and seminars, such as those hosted by the Council on State Taxation, residency case. Tax Executives Institute, and Institute for Professionals in Taxation, as well as local conferences such as those hosted by the Chicago Tax Club. Perspectives. The diverse perspectives of our attorneys bring the optimal mix of sharp legal skills and practical know-how to every client relationship and engagement. Our attorneys bring experience from industry, government, the Big 4 accounting firms, and in-house positions, with years of litigation experience at all levels of appeal, from administrative proceedings to the United States Supreme Court. In government, we have held the following key positions: Chief r e e d s m i t h . c o m State Tax 2017
ReedSmith State Tax Practice Counsel, California Franchise Tax Board; General Counsel, Illinois Department of Revenue; Success Stories Deputy Commissioner of Revenue, State of Alaska; Acting and Deputy Chief, Illinois Attorney General’s Revenue Litigation Division; Legal Counsel to a California State Board of Legislative and Equalization board member; and Deputy Commissioner and Taxpayer Rights Advocate, New Regulatory Guidance: York State Department of Taxation and Finance. Facilitated a meeting between a top New Serving Clients Jersey official and clients following passage of the When we earn the privilege to help our clients, we approach each engagement with great state’s Business Tax care. We assign attorneys with the right skill sets to each engagement, immerse ourselves in Reform Act. The meeting our clients’ facts and circumstances, and deliver our work product using technology to be cost- provided the opportunity effective, efficient, transparent and responsive. to gain valuable insight as to how the new act would Fee Flexibility & Cost Savings. Our practice offers a flexible approach to billing and fees. be interpreted. We then We have the ability to structure matters based on contingency-based billing, risk-sharing helped position our clients agreements, and other arrangements tailored to meet client needs and internal corporate advantageously under the policies. new act. National Platform. Reed Smith has the largest number of dedicated state tax attorneys in Nationwide Resolution: any law firm, with our attorneys located in offices across the United States. The location and Developed and executed a 50-state resolution experience of our team allows us to coordinate state tax issues and advise on a national level strategy for a Fortune 100 to help clients avoid decisions made in one jurisdiction, from having unintended tax company in addressing consequences in other jurisdictions. state actions aimed at intangible holding Tax Intelligence. The size of our team allows us to track local developments across the companies. Strategy country, even though several states do not publish their tax practices and policies. Through eliminated nearly $100 our Tax Intelligence system, we track key issues state-by-state. Our team has collected more million of potential tax than 7,000 records that are not readily available through commercial sources, including case exposure by participating filings, unreported decisions and other key documents. Knowing these developments in in early voluntary advance allows us to bring opportunities to our clients earlier than other service providers. compliance programs, pursuing amnesty Seamless Information-Sharing & Efficiency Through Technology. opportunities, negotiating favorable settlements, and ouRSite. Our client-specific extranet site, ouRSite, is a free service that we offer to any assisting with analysis of client, for any matter, providing 100 percent real-time access to documents related to their Uncertain Tax Positions. matters. Clients also have the ability to add documents to the site, initiate conversations, and post issues for the team to consider. An ouRSite portal does not eliminate the personal communication between our lawyers and clients; it simply enhances the agility of the client/lawyer team by creating the visibility to our work at the convenience of the client. r e e d s m i t h . c o m State Tax 2017
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