practices
Our experts in various fields find solutions for customers. We provide customized solutions based on a thoroughly analyzed litigation database.
State & Local Tax(SALT)
Comprehensive Counsel for Complex Multistate Tax Matters
In today’s regulatory environment, state and local tax (SALT) issues have grown increasingly complex, overlapping across jurisdictions and creating material risks for businesses and individuals alike. From corporate income and franchise tax disputes to sales, property, and excise tax audits, navigating the intricacies of state and municipal tax systems demands experienced legal guidance.
At SJKP LLP, our State & Local Tax team provides strategic advice, dispute resolution, and planning services across all 50 states. We combine deep knowledge of tax policy and litigation with firsthand experience in government agencies and major accounting firms. Whether advising on multistate tax compliance, representing clients in audits and appeals, or shaping legislative policy, we deliver clarity and results in a constantly shifting tax landscape.
contents
1. The State & Local Tax Landscape
Evolving Rules, Expanding Jurisdictions, and Increased Enforcement
The U.S. SALT environment is defined by continuous change. States and municipalities are becoming more aggressive in asserting nexus, broadening tax bases, and expanding digital and remote activity taxation. Businesses must now account for differing apportionment formulas, economic nexus standards, and local filing obligations that can vary dramatically from state to state.
SJKP LLP helps clients understand these complex frameworks and anticipate changes before they occur. We monitor legislative updates, regulatory developments, and judicial trends across all jurisdictions—advising on their implications for business operations, investment structures, and transaction planning.
Emerging Trends in SALT Enforcement
- - Economic Nexus Expansion:
- Following South Dakota v. Wayfair, states are increasingly enforcing sales and use tax obligations on remote sellers, digital services, and e-commerce platforms.
- Digital Goods & Cloud Taxation:
Jurisdictions are implementing new frameworks for taxing SaaS, digital advertising, and cloud-based transactions, often with inconsistent rules.
- Apportionment & Sourcing Reforms:
States continue to refine their corporate tax formulas, emphasizing market-based sourcing and combined reporting.
- Increased Audit Activity:
Revenue agencies are deploying data analytics and information-sharing programs to identify compliance gaps, leading to higher audit frequency.
Our attorneys assist clients in responding to these evolving enforcement strategies and designing tax positions that withstand scrutiny.
2. SALT Planning and Compliance
Proactive Strategies to Minimize Risk and Optimize Tax Efficiency
Effective SALT management requires more than compliance—it demands foresight. We help clients structure operations, transactions, and expansions in a way that aligns with each jurisdiction’s laws while optimizing overall tax efficiency.
Our team provides strategic guidance on multistate corporate structuring, tax credit utilization, and transactional planning. We also advise individuals and family offices on residency, domicile, and wealth transfer considerations that carry significant state-level implications.
Strategic SALT Services
- - Multistate income, franchise, and gross receipts tax planning.
- Nexus and apportionment analysis for expanding or remote businesses.
- Sales and use tax compliance for e-commerce and digital service providers.
- Property, excise, and utility tax assessments and exemptions.
- Incentive, credit, and economic development negotiations.
- Residency and domicile planning for high-net-worth individuals.
We emphasize preventive strategies that reduce exposure and enhance financial predictability across jurisdictions.
3. SALT Controversy and Litigation
Defending Clients Across All Stages of Tax Dispute Resolution
When controversy arises, SJKP LLP’s attorneys manage every phase of the process—from audit to appeal to litigation. We represent clients before administrative agencies, state tax tribunals, and appellate courts nationwide. Our litigation-focused approach enables us to resolve disputes efficiently while protecting long-term relationships with tax authorities.
Our SALT litigators have handled matters involving corporate income, sales and use, property, excise, and gross receipts taxes, achieving favorable results in high-stakes cases involving millions of dollars. By combining deep procedural understanding with technical tax analysis, we deliver decisive advocacy that drives results.
Litigation and Dispute Resolution Experience
- - Representation in state and local income, franchise, and sales tax litigation.
- Defense against audit assessments and penalty disputes.
- Negotiation of voluntary disclosure agreements and settlement resolutions.
- Appeals before state courts and administrative boards.
- Amicus advocacy in precedent-setting SALT cases.
We also maintain strong working relationships with revenue officials and auditors nationwide, allowing us to pursue practical, results-oriented resolutions whenever possible.
4. Multistate Reach and Interdisciplinary Experience
Nationwide Capability, Local Understanding
Our SALT team operates across all 50 states, providing seamless support wherever our clients conduct business. With attorneys who have served in state tax agencies, departments of justice, and major accounting firms, we bring insight from every side of the table.
This unique perspective enables us to anticipate regulators’ strategies and tailor defense approaches accordingly. We also collaborate closely with our firm’s corporate, real estate, and M&A practices to ensure that tax implications are integrated into every transaction and business decision.
Government and Industry Experience
Our team includes former counsel and advisors from:
- - State Departments of Revenue and Franchise Tax Boards.
- State Boards of Equalization and Attorney General Tax Divisions.
- Leading Big Four accounting firms and Fortune 500 corporate tax departments.
This diversity of experience allows us to translate technical regulations into actionable business strategies.
5. Legislative Advocacy and Policy Insight
Shaping the Future of State and Local Tax Law
SJKP LLP’s attorneys are not only practitioners but also thought leaders in tax policy. We work with legislators, industry associations, and policy groups to shape fair and effective tax frameworks. Our advocacy extends to drafting legislation, submitting amicus briefs, and testifying before administrative and judicial bodies on matters of public importance.
By engaging proactively in the legislative process, we help ensure that our clients’ interests are represented before laws are enacted—reducing future compliance burdens and litigation risk.
Public Policy and Legislative Engagement
- - Drafting and analyzing proposed state tax legislation.
- Advocating for modernization of outdated tax systems.
- Advising industry coalitions on multistate tax policy reform.
- Contributing to public hearings and comment processes.
- Publishing thought leadership on state and local tax developments.
Our proactive involvement allows us to anticipate regulatory shifts and position clients advantageously within evolving tax systems.
6. Why Choose SJKP LLP for SALT Counsel
Experience. Advocacy. Results.
State and local tax challenges demand counsel who understand not just the law but also the realities of enforcement, negotiation, and litigation. SJKP LLP’s SALT team brings together deep technical skill, broad geographic coverage, and proven success in the most complex cases.
We represent businesses, investors, and individuals across industries—from technology and energy to finance and manufacturing—offering tailored solutions that align tax strategy with business goals. Whether defending a high-stakes audit, planning a multistate expansion, or shaping future tax policy, we deliver practical guidance grounded in legal precision and strategic foresight.
Our mission is simple: to help clients navigate complexity, resolve disputes, and achieve lasting tax efficiency in every jurisdiction where they operate.
The information provided in this article is for general informational purposes only and does not constitute legal advice. Reading or relying on the contents of this article does not create an attorney-client relationship with our firm. For advice regarding your specific situation, please consult a qualified attorney licensed in your jurisdiction.
Certain informational content on this website may utilize technology-assisted drafting tools and is subject to attorney review.
