Services
Focused representation across the full lifecycle of a multistate sales and use tax issue — scoped to what's actually material to your business, not padded to fill an engagement letter.
Every engagement starts with one question: what decision are you trying to make?
Before any work begins, we identify the actual business decision on the table — register or don't, fight the audit or settle it, disclose or hold — and scope the work to answer that question as efficiently as possible. If the analysis along the way turns up something bigger, you'll hear about it directly. If it doesn't, the engagement ends instead of expanding to find something.
Where most engagements start
The three areas where clients most often need a fast, material answer — and where nearly two decades of focused experience makes the biggest difference.
State Tax Audit Defense
When a state auditor opens an examination, the way that process is managed from day one often determines the outcome. Kyle represents businesses throughout state sales and use tax audits — managing information requests, framing the taxpayer's position, and negotiating with auditors and appeals officers to reach a fair resolution efficiently. Where litigation genuinely makes business sense, we pursue formal administrative appeal — but that's a last resort, not a default.
- Response strategy for audit notices and information requests
- Direct negotiation with state revenue departments
- Administrative appeals and settlement negotiation
- Coordination with outside accountants and in-house tax teams
Reverse Audits & Refund Review
Overpayment of sales and use tax is far more common than most businesses realize — particularly for companies with complex purchasing, exemption certificate management, or multistate operations. We conduct structured reverse audits of historical transactions to identify overpayments, prepare and file refund claims, and pursue recovery through the applicable state process — targeting the areas most likely to yield real dollars back, not a line-by-line fishing expedition.
- Transaction-level review of accounts payable and use tax accruals
- Exemption and resale certificate analysis
- Refund claim preparation and filing
- Advocacy through state refund review and appeal processes
Voluntary Disclosure Agreements
Businesses that discover historical nexus or filing exposure have options short of waiting for an audit. We negotiate voluntary disclosure agreements with state revenue departments on an anonymous basis where available, limiting look-back periods and mitigating or eliminating penalties, so your business can come into compliance on manageable, known terms — instead of an open-ended liability.
- Anonymous, pre-filing negotiation where available
- Limitation of look-back periods and penalty exposure
- Coordinated multistate VDA strategy
The complete range of SALT counsel
Beyond the core, the full set of multistate sales and use tax services available to your business and in-house teams.
Nexus Determination
Since South Dakota v. Wayfair, economic nexus thresholds mean a business can trigger a sales tax collection obligation in a state where it has no physical presence at all. We analyze your sales activity, marketplace facilitator exposure, and physical footprint across all fifty states to determine where you've actually established nexus — not every state where a theoretical argument could be made — and give you a straight answer on what it means for compliance.
- Economic and physical nexus analysis, state by state
- Marketplace facilitator and click-through nexus considerations
- Practical roadmaps for registration and compliance, prioritized by real exposure
Taxability Research & Legal Opinions
Sales tax treatment of products and services varies widely from state to state, and the rules are rarely intuitive. We research and document the taxability of your products, services, and bundled transactions — including mixed-transaction and "true object" questions — and prepare formal legal opinions that support your compliance positions and can help protect against penalties.
- Product and service taxability matrices
- Formal legal opinions on tax treatment
- Support for exemption and resale certificate programs
Multistate Compliance & Process Improvement
Long-term compliance is as much a process problem as a legal one. We evaluate existing sales and use tax compliance processes and recommend practical, technology-enabled improvements that reduce ongoing risk without adding headcount — plus targeted training for internal tax, finance, and accounting teams.
- Process review and improvement recommendations
- Technology and automation guidance for compliance
- Custom training sessions for internal teams
Transactional SALT Due Diligence
State and local tax exposure can materially affect the value of a transaction. We advise buyers, sellers, and investors on the SALT implications of mergers, acquisitions, and entity restructuring, including targeted due diligence to surface historical exposure before it becomes the acquirer's problem — sized to the deal timeline, not a standalone audit.
- SALT due diligence for M&A transactions
- Entity restructuring and successor liability analysis
- Deal-stage risk quantification and mitigation strategy
General SALT Advisory
Not every question requires a formal engagement. We're available as an ongoing, on-call resource for in-house tax and legal departments navigating day-to-day multistate sales and use tax questions — including a second opinion when another advisor's answer feels padded or overly cautious.
- On-call advisory support for in-house teams
- Monitoring of state legislative and administrative developments
- Second-opinion review of existing tax positions
Experience across complex, regulated, and multistate industries
Financial services and banking · payment processors · insurance · fintech · healthcare · manufacturing · retail and e-commerce · construction · technology and SaaS — from private, closely held businesses to Fortune 100 companies.
Not sure which service you need?
Most engagements start with a conversation, not a fixed scope. Reach out and we'll help you identify the right first step — including telling you if you don't need one.
Schedule a ConsultationHave a quick SALT question — nexus, an audit notice, a VDA? Ask in a short, no-pressure consultation →