Recent Matters

  • Represented major telecommunications service provider in US$24 million California income apportionment dispute
  • Obtained a favorable result in a Texas unitary business hearing that overturned the original audit assessment
  • Obtained a complete reversal of an audit assessment in a Washington sales tax and business and occupations tax dispute involving an out-of-state telecommunications business
  • Assisted a manufacturer of electronic vehicles with US state income tax planning
  • Revised existing operational structure to minimize sales and use tax collection obligations for company engaged in e-commerce marketplace transactions
  • Developed legal analysis and strategy to support sales and use tax nexus position of nationwide consumer equipment seller engaged in online and in-store transactions
  • Analyzed tax issues for successful appeal of a small business stock case before the California Supreme Court
  • Assisted California equipment wholesaler with structure of distributor/reseller arrangements to minimize state sales tax collection obligations
  • Counseled a major retailer in the formation of an intangible holding company and establishment of a gift card program to maximize unclaimed property benefits
  • Obtained a favorable settlement in a US$2 million California tax dispute regarding the unitary nature of a taxpayer’s commercial technology and government contracting businesses
  • Developed a position for telecommunications equipment manufacturer in opposition to auditors position regarding impact of stock option exercise by employee spouse on state income tax apportionment factors
  • Advised a California software provider on the tax ramifications of establishing software development operations in other states
  • Prepared a successful tax appeal in a case before the California State Board of Equalization for defense contractor concerning business/nonbusiness income characterization arising from the sale of stock
  • Successfully represented a taxpayer in a dispute before the California State Board of Equalization regarding inadequate taxpayer notification of an assessment by the Franchise Tax Board
  • Represented a husband and wife in a successful multi-million dollar California residency tax dispute