State & Local Tax Transactions Informed Guidance
Understanding overly complicated state and local tax laws goes beyond the fundamentals. At Kilpatrick, our attorneys provide transactional and technical advice to businesses seeking to comply with often unclear state tax laws and vague administrative guidance. We advise buyers and sellers on the state and local tax aspects of complex transactions, including whether transactions are subject to sales tax and real property transfer tax, and we provide due diligence to buyers to ensure that no hidden state tax landmines accompany the purchase. Upon request, we consider the go-forward implications of transactions for acquirers. For businesses expanding or creating a footprint in a state, we work to obtain statutory and discretionary state and local tax incentives and benefits. Our representation of sellers includes determining how to source transaction proceeds for sales tax and corporate income tax purposes and ascertaining whether gain from a sale is apportionable or allocable for state corporate income tax purposes.
Experience
Assisted a Fortune 100 company in determining whether gain from the sale of a discrete business line was apportionable or allocable income in a significant number of states.
Obtained voluntary disclosure agreements in over 20 states for the seller of a business.
Obtained a favorable Virginia income apportionment ruling for a financial institution.
Advised taxpayers on sales tax issues relating to purchases of aircraft, artwork, and other valuable assets.
Obtained a favorable New York advisory opinion, concluding taxpayer’s service were not subject to New York sales tax.
Obtained voluntary disclosure agreements for several companies through the Multistate Tax Commission’s National Nexus Program.
Performed a nexus review for a technology company and obtained voluntary disclosure agreements in various states.
Advised taxpayer on the extent to which online services are subject to sales tax in various states.
Insights
Publication
Getting The Deal Through | State and Local Taxes: USA – Georgia
News Releases
Kilpatrick Townsend Earns Sweeping Recognition in 2024 Edition of Best Law Firms®
News Releases
Significant Number of Kilpatrick Townsend Attorneys Recognized in 2024 Best Lawyers: Ones to Watch
Publication
NY Regs Seek Narrow Protections from Tax on E-Commerce
Perspectives
Corporate Connection Q2 2023
News Releases
Kilpatrick Townsend Attorneys Earn Record Number of Rankings in 2023 Chambers USA
Primary Contacts View All
Disclaimer
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.
