ReedSmith State Tax Practice For more information about Exceptional Experience our group, please visit www.reedsmith.com/state Reed Smith’s State Tax Practice has more professionals exclusively focused on state tax tax/ or contact: issues than any other U.S. law firm. Devoted to the full range of state tax matters, we do more Lee A. Zoeller, Partner than address individual issues as they arise. Our emphasis is on building strong client Practice Group Leader relationships, so we work to create comprehensive solutions that enable our clients to focus +1 215 851 8850 on moving ahead. This has resulted in our representation of more than 10 percent of the [email protected] Fortune 500 companies in state tax matters, and recognition by tax and business organizations, including The Wall Street Journal. Reed Smith Offices: Reed Smith’s state tax lawyers serve clients by leveraging a national platform with deep tax Abu Dhabi technical and industry experience. Our lawyers have diverse backgrounds, allowing us to Athens understand more about our clients and their needs, and not solely the laws impacting them. Beijing This depth and breadth of knowledge impacts how we address client issues – balancing the Century City law against the economic, business, and social environments in which our clients work every Chicago day. Dubai Scope of Services Frankfurt Hong Kong Our services include not only traditional legal services of audit defense and appeals – litigating Houston from the earliest of administrative levels all the way through to the United States Supreme Kazakhstan Court – but also nearly all areas of tax consulting. London Los Angeles Controversy & Litigation. Our controversy and litigation work encompasses all states and Munich all taxes, with particular emphasis in income/franchise tax, sales/use tax, real/personal New York property tax, and gross receipts taxes, such as the Texas Margins Tax and Washington B&O, Paris and Unclaimed Property. We assist clients with state tax controversies at the audit level, and Philadelphia represent clients at all administrative levels, federal and state courts, including the United Pittsburgh States Supreme Court. Because we understand that it is more cost effective for clients to Princeton conclude a matter as early as possible in the controversy process, we work diligently to Richmond achieve favorable settlement. As needed, we will defend clients through all judicial levels until San Francisco our clients’ goals are met. Representative matters are listed at the end and highlighted Shanghai throughout this brochure. Silicon Valley Our consulting work mirrors the subject-matter experience of our Singapore Tax Consulting. controversy and litigation work. Our ability to deliver consulting work differentiates our services Tysons from many other law firms. Our services include: Washington, D.C. Wilmington Performing multistate tax refund reviews Modeling multistate impact of changing tax laws and business facts reedsmith.com State Tax 2017 ReedSmith State Tax Practice Developing and implementing state tax minimization strategies for transactional Success Stories activity or general tax liabilities Rare Victories for Conducting and documenting FIN 48 reviews Intangible Holding Company Structures: Monitoring and advocating legislative, regulatory and other legal developments Prevailed in resolving Drafting legislation and regulations numerous cases involving Identifying, negotiating and implementing credits and incentives the intangible holding Developing unclaimed property reporting positions company of a major nationwide retailer and Developing compliance programs entities. Similarly helped Executing voluntary disclosure initiatives several clients facing tax Obtaining ad valorem tax exemptions, including through appeal exposures of tens of millions of dollars in New Assisting with public relations issues resulting from tax matters Jersey in a dispute involving intangible holding Recognized Leaders and Diverse Perspectives companies. Because we remain on the cutting edge of developments and changes in state tax, we are Record Settlements for regularly recognized by legal and business communities, hold leadership positions in leading Industry and Individuals: state tax organizations, and are sought out to speak at local and national tax seminars and Obtained the largest conferences. income tax refund settlement for a bank Legal/Business Recognitions. Our experience has been highlighted by Legal 500, The taxpayer; large settlements Wall Street Journal, Forbes, NetworkWorld, E-Commerce Times, The Hartford Courant, State for a pharmaceutical company in Illinois; some Tax Notes and BusinessWeek. of the largest oil and gas Leadership Positions. We serve in leadership positions for the Institute for Professionals company cases to come in Taxation, Taxpayers’ Federation of Illinois, the State Income Tax Monitor, and the Journal before the California Franchise Tax Board; and of Multistate Taxation. helped settle the largest Speaking Engagements. Our attorneys are regularly invited speakers at national and personal income tax residency case. regional conferences and seminars, such as those hosted by the Council on State Taxation, Tax Executives Institute, and Institute for Professionals in Taxation, as well as local conferences such as those hosted by the Chicago Tax Club. Perspectives. The diverse perspectives of our attorneys bring the optimal mix of sharp legal skills and practical know-how to every client relationship and engagement. Our attorneys bring experience from industry, government, the Big 4 accounting firms, and in-house positions, with years of litigation experience at all levels of appeal, from administrative proceedings to the United States Supreme Court. In government, we have held the following key positions: Chief reedsmith.com State Tax 2017 ReedSmith State Tax Practice Counsel, California Franchise Tax Board; General Counsel, Illinois Department of Revenue; Success Stories Deputy Commissioner of Revenue, State of Alaska; Acting and Deputy Chief, Illinois Attorney General’s Revenue Litigation Division; Legal Counsel to a California State Board of Legislative and Equalization board member; and Deputy Commissioner and Taxpayer Rights Advocate, New Regulatory Guidance: Facilitated a meeting York State Department of Taxation and Finance. between a top New Jersey official and clients Serving Clients following passage of the When we earn the privilege to help our clients, we approach each engagement with great state’s Business Tax care. We assign attorneys with the right skill sets to each engagement, immerse ourselves in Reform Act. The meeting provided the opportunity our clients’ facts and circumstances, and deliver our work product using technology to be cost- to gain valuable insight as effective, efficient, transparent and responsive. to how the new act would Fee Flexibility & Cost Savings. Our practice offers a flexible approach to billing and fees. be interpreted. We then helped position our clients We have the ability to structure matters based on contingency-based billing, risk-sharing advantageously under the agreements, and other arrangements tailored to meet client needs and internal corporate new act. policies. Nationwide Resolution: National Platform. Reed Smith has the largest number of dedicated state tax attorneys in Developed and executed any law firm, with our attorneys located in offices across the United States. The location and a 50-state resolution experience of our team allows us to coordinate state tax issues and advise on a national level strategy for a Fortune 100 to help clients avoid decisions made in one jurisdiction, from having unintended tax company in addressing consequences in other jurisdictions. state actions aimed at intangible holding Tax Intelligence. The size of our team allows us to track local developments across the companies. Strategy country, even though several states do not publish their tax practices and policies. Through eliminated nearly $100 our Tax Intelligence system, we track key issues state-by-state. Our team has collected more million of potential tax than 7,000 records that are not readily available through commercial sources, including case exposure by participating filings, unreported decisions and other key documents. Knowing these developments in in early voluntary advance allows us to bring opportunities to our clients earlier than other service providers. compliance programs, pursuing amnesty Seamless Information-Sharing & Efficiency Through Technology. opportunities, negotiating favorable settlements, and ouRSite. Our client-specific extranet site, ouRSite, is a free service that we offer to any assisting with analysis of client, for any matter, providing 100 percent real-time access to documents related to their Uncertain Tax Positions. matters. Clients also have the ability to add documents to the site, initiate conversations, and post issues for the team to consider. An ouRSite portal does not eliminate the personal communication between our lawyers and clients; it simply enhances the agility of the client/lawyer team by creating the visibility to our work at the convenience of the client. reedsmith.com State Tax 2017 ReedSmith State Tax Practice DealBuilder. Our group has customized its DealBuilder technology to ensure our clients’ Success Stories controversial matters are handled more efficiently, providing the advantage of quicker Public Relations: turnaround time and