State and Local Tax
- Holland & Knight's State and Local Tax (SALT) Team provides multistate planning, SALT compliance, audit defense and representation in controversies across the U.S., assisting clients every step of the way and delivering proactive solutions and controversy support where needed.
- We provide advice on SALT issues in transactional matters, including mergers and acquisitions (M&A), multistate real estate acquisition and finance transactions, and business aviation structuring.
- Our SALT Team serves a variety of industries – including energy, financial services, real estate, transportation, retail, healthcare and tech clients – and handles income, franchise, property, excise and sales tax matters to maximize state and local tax credits and incentives, with deep experience in key jurisdictions such as California, Florida, Texas, Pennsylvania and New York.
Overview
Trusted Advisors for SALT Strategy, Compliance and Controversy
Holland & Knight's State and Local Tax (SALT) Team provides nationwide legal counsel across the full spectrum of state and local tax issues.
Our experienced attorneys help businesses and individuals structure transactions for optimal state and local tax efficiency. Our team also advocates for clients in disputes with taxing authorities – from audit defense through administrative and judicial appeals – and has appeared before trial courts, appellate courts, state supreme courts and the U.S. Supreme Court.
In addition, we help businesses navigate their nexus with taxing jurisdictions, address apportionment and sourcing issues, analyze the constitutionality of states' laws and assessments, and develop comprehensive SALT planning strategies. We also advise on SALT cap workarounds and implications for pass-through entities, SALT implications of remote employees and unclaimed property compliance. Our SALT lawyers help ensure full compliance and help clients stay ahead of evolving regulations through tailored planning and defense strategies.
SALT Planning and Compliance
Holland & Knight's SALT attorneys help businesses and individuals proactively manage their state and local tax obligations. Our services include:
- sales tax controversy, planning and compliance support, including:
- advice on nexus with state and local jurisdictions, including economic nexus
- analyzing marketplace facilitator laws
- reviewing digital goods and services to determine taxability
- income tax controversy, planning and compliance support, including:
- apportionment and sourcing analysis and defense
- Public Law 86-272 analysis and defense
- domicile planning and tax residency defense
- miscellaneous tax controversy, planning and compliance support related to gross receipts and utilities taxes, local business taxes and property taxes
- analysis of SALT implications of remote employees
- state and local tax planning to maximize deductions and minimize liabilities
- guidance on SALT deduction strategies and SALT cap workaround options
- advice on real estate transfer tax matters in Florida, New York, California and other key jurisdictions
- structure of business aircraft acquisitions to ensure SALT compliance
- identification and implementation of SALT planning opportunities in finance transactions
- assistance with SALT Voluntary Disclosure programs
- assistance with unclaimed property compliance
Additionally, our attorneys counsel clients on state and local tax credits, incentives and deductions available to businesses across industries.
SALT Controversy and Audit Defense
Facing a state or local tax audit? Our SALT lawyers provide strategic representation throughout the audit and appeals process. We handle:
- state and local tax audits and controversies
- appeals before administrative bodies and courts
- resolution strategies, including voluntary disclosure programs
- defense in disputes involving property tax, sales tax, income tax, gross receipts taxes, stamp taxes and local business taxes
Industry Experience and Geographic Reach
Our SALT Team serves clients in key industries such as energy, financial services, real estate, transportation, manufacturing, retail, technology, healthcare and software. We have deep experience in high-impact jurisdictions, including California, Florida, New York, Pennsylvania, Texas and many others, ensuring that our clients can rely on us for their SALT issues throughout the U.S.
Thought Leadership and Resources
Our attorneys regularly publish insights and speak on trending SALT topics, including:
- defense strategies in SALT controversies and litigation
- how businesses can navigate economic nexus and audit triggers
- SALT implications of remote workforces and digital services
- planning for SALT issues in M&A, aircraft and real estate transactions
- strategic use of pass-through entity tax (PTET) workaround
- industry-specific SALT credits and incentives
- legislative impacts from the One Big Beautiful Bill Act (OBBB)
