State and Local Tax Controversy

Sidley’s State and Local Tax (SALT) Controversy practice represents clients in tax controversies in various states and municipalities at all stages of the administrative process, from audit through administrative appeal, and at every judicial level, from trial court to the United States Supreme Court.

A particular facet of our practice is favorably resolving disputes without litigation. We believe that by resolving disputes at the earliest stage, we are able to provide our clients with favorable resolution of their tax dispute without the additional costs, distraction of internal resources and publicity that necessarily accompany any formal tax litigation. In recent years, we have resolved many issues on favorable terms before the dispute has advanced to litigation.

On disputes that we are unable to resolve at the informal levels, and for clients that retain us after exhausting their informal settlement opportunities, we assist each client in selecting the appropriate forum for the client’s particular tax issue. We then rely upon a team of experienced trial lawyers and tax professionals to either reach a favorable settlement with the government attorneys or prosecute the tax claims through trial and, if necessary, appeals.