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.
In recent years, we have resolved many issues on favorable terms before the dispute has advanced to litigation, whenever it was advantageous to our clients, including, where appropriate, by obtaining private letter rulings from multiple jurisdictions or negotiating voluntary disclosure agreements with multiple jurisdictions. We have developed strong working relationships with state taxing authorities in numerous jurisdictions throughout the United States, without compromising our ability to defend the rights of our clients.
For disputes that are not resolved administratively during the audit or appeals process, and for clients that retain us after the conclusion of the administrative process, we have substantial experience with state tax litigation in administrative and judicial proceedings. We assist each client in selecting the appropriate forum for the client’s particular tax issue. We then rely upon a team of experienced state tax litigators to prosecute the tax claims through trial and, if necessary, appeals, while always being alert for additional settlement opportunities.