Practice Areas

State Income and Franchise Tax

Whether it is providing assistance with a tax audit, creating and implementing a tax-efficient corporate structure, or performing a due diligence review, Ryan delivers strategic solutions for minimizing state income and franchise tax.

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Mark L. Nachbar

Principal

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June 4, 2017

State Income Tax School II

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State Income and Franchise Tax

The pressure on corporate tax departments is coming from every direction. State income and franchise tax authorities have become very aggressive and are increasing the frequency and depth of their audits. In addition, state legislators are implementing new statutes or promulgating new rules, most of which are targeted at the elimination of perceived tax “loopholes.”

Ryan can provide tremendous value through technical expertise and best-in-class client service. Whether it is providing assistance with a state income/franchise tax audit, helping your company create and implement a tax-efficient corporate structure, or performing a due diligence review for your acquisition or merger, we focus on finding cost-effective ways to save tax dollars and improve the effectiveness and efficiency of your tax function.

Our comprehensive approach to identifying tax-saving opportunities includes:

  • Analyzing tax calculations, including applicable federal income tax implications
  • Examining alternative or optimal filing methodologies
  • Reviewing formulary apportionment calculations, including alternative apportionment factor methodologies and throwback or throwout calculations

Ryan manages the audit process from beginning to end, ensuring that we minimize our client’s burden to the fullest extent possible. Our professionals handle the arduous process of producing records for the state and securing files required to build the case, determining which issues merit an appeal and the likelihood of success for each. We manage the day-to-day information flow between our client and the taxing authority to ensure timely, complete, and accurate responses and assist with accelerated dispute resolution processes to reduce the costs and other burdens associated with audit defense activities. As needed, we meet with auditors, dispute resolution officers, administrative hearings attorneys, and other agents to clearly identify all positions that impact our client’s ability to achieve a favorable outcome. 

Services Provided

Ryan represents our clients’ interests during tax audits to ensure they pay only their fair share of taxes. Our Audit Representation provides a comprehensive range of services, including:

  • Audit coordination
  • Audit review and opportunity assessment
  • Audit sampling analysis and evaluation
  • Controversies and appeals
  • Responses for information and document requests
  • Risk assessments
  • Tax audit representation
  • Tax compliance and reporting evaluation
  • Taxability determinations
  • Voluntary disclosure and registration

Ryan is dedicated to resolving tax disputes expeditiously by assisting clients with controversy resolution and legislative services, as well as protecting the rights of taxpayers through honest and fair public policy. We’re aggressive but professional. We understand the importance of constructive relationships with taxing authorities. We also understand that respect is earned. From informal conferences to administrative level appeals, our goal is to resolve tax controversies quickly and professionally. And when disputes can’t be resolved through simple negotiation, we’re prepared to fight for our clients’ interests for as long as it takes.

Ryan’s Strategic Planning services focus on our client’s overall tax performance, creating greater opportunities to measure and improve efficiency, develop a more strategic approach to tax, and deliver outstanding shareholder value. Through benchmarking current performance, identifying best practices in relation to peer and historical performance, and measuring the delta between reality and the potential of our client’s tax department, Ryan provides a clear strategic plan for transforming the tax function into a Tax Competency Center.

Ryan professionals help our clients plan and implement processes and technologies that improve the efficiency and effectiveness of their tax operations. We assess tax positions and develop strategic plans that include transaction structuring, business reorganization, and alternative filing positions. And we ensure that the efforts of our clients' tax departments are positively impacting the overall strategic objectives of their organizations. 

Services Provided
Ryan leverages years of experience and best practices to help our clients design and implement proven planning strategies for mitigating risk, minimizing tax liabilities, and improving efficiency and effectiveness through a suite of services, including:

  • Alternative filing positions
  • Business reorganization
  • Risk mitigation planning
  • Strategic business planning
  • Tax automation
  • Total performance assessments
  • Transaction structuring
  • Workflow assessments and solutions

Ryan’s Tax Compliance professionals provide a breadth of expertise in tax administration and process improvement to help clients effectively manage their compliance processes and focus on a broader strategic vision for total tax performance. Functioning as an extension of our client’s tax department, we offer a full suite of compliance and automation solutions that streamline internal tax operations, including managing costs and employee resources, eliminating manual processes, minimizing overpayments and errors on returns, and reducing risk and the likelihood of notices and penalties.

At Ryan, we don’t simply review our clients’ records for tax recovery and tax-saving opportunities; we scour them. We understand the complex environments in which our clients operate. We understand the unique provisions of the tax codes in the jurisdictions where they conduct business. We stay current with the latest rulings and changes in tax law as they apply to our clients’ businesses. And our efforts translate into significant tax savings and superior results for our clients.  Simply put, our commitment to excellence and utilization of sophisticated technology ensure that we’re more thorough, efficient, and effective than our competitors.

Ryan professionals target every possible tax refund and reduction opportunity for our clients. We commit every day to sifting through, drilling down, and peeling back the intricacies of federal, state, local and international tax to discover truly significant recovery opportunities. And we focus on reducing our clients’ tax liabilities with minimum disruption to their operations, requiring only limited effort from their personnel. 

Ryan’s Tax Research services cut through complicated and constantly changing state and local tax rules to uncover the issues that truly matter to our clients. Our researchers not only analyze the law, they evaluate and verify individual circumstances to apply the law to each possible scenario. 

Our seasoned professionals are well versed in preparing tax matrices for all types of industries, writing opinion letters on the tax consequences of complex and unusual transactions, preparing requests for administrative rulings on intricate issues, determining nexus and filing requirements, and reviewing specific transactions to ensure that our tax decision solutions are accurate and consistent. Additionally, we provide research and update services to the taxability matrices we develop.

Services Provided

Ryan has an experienced team of professionals that research complex and evolving tax issues, legislation, and developments to identify and address the potential tax implications of multi-jurisdictional operations. Our Tax Research services include:

  • Nexus determinations and filing requirements
  • Opinion letters
  • Requests for administrative rulings
  • System configurations
  • Tax matrices
  • Training

Integrated End-to-End Tax Services

Ryan is focused on your overall tax performance—providing innovative solutions to the underlying causes of the errors we identify—and creating greater opportunities to measure and improve your efficiency, develop a more strategic approach to tax, and deliver outstanding value to your shareholders.