SALT Controversy Strategies from Audits through Litigation

Date: April 30, 2020

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Hosted By: Fredrikson & Byron’s Tax Disputes & Litigation Group


Kyle Brehm
Masha Yevzelman

Program Description:

State tax controversy can present daunting strategy issues for taxpayers as well as service providers. This session focuses on preparing for controversy prior to audit division involvement and discusses potential strategies for defending a taxpayer position throughout the agency review phases (both audit and appeal).

However, rather than viewing agency review in a vacuum, this session also discusses how to guide the agency review phases in a manner that sets up taxpayers to successfully litigate their issues, in the event that that becomes the only remaining option.

After this webinar, listeners will be able to:

  • Understand the different phases of controversy, from preparation through agency review, and ultimately litigation.
  • Analyze strategies for controversial issues in light of their impact on later phases within the controversy lifecycle.
  • Understand the limitations facing taxpayers and service providers at different phases within the controversy lifecycle.