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Securities and governance litigation insights

Our experience covers all tax types, including income, franchise, sales, property and excise taxes. Our state tax attorneys regularly litigate state and local tax cases throughout the country. We help clients, particularly those with multistate operations, design tax-efficient structures. We also assist clients in negotiating state and local tax incentives, defending unclaimed property (escheat) audits, and proactively addressing client needs through letter rulings and legislative support.

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Our experience covers all tax types, including income, franchise, sales, property and excise taxes. Our state tax attorneys regularly litigate state and local tax cases throughout the country. We help clients, particularly those with multistate operations, design tax-efficient structures. We also assist clients in negotiating state and local tax incentives, defending unclaimed property (escheat) audits, and proactively addressing client needs through letter rulings and legislative support.

Tax controversy and litigation

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In a village of La Mancha, the name of which I have no desire to call to mind, there lived not long since one of those gentlemen that keep a lance in the lance-rack, an old buckler, a lean hack, and a greyhound for coursing.

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Tax controversy and litigation

Our attorneys defend companies against aggressive tax audits conducted by tax agencies throughout the country. When these matters cannot be resolved in audit, we litigate state tax cases before administrative tribunals and in state trial and appellate courts. Large companies with multistate operations look to us to develop and manage consistent litigation strategies on a national basis.

Our attorneys defend companies against aggressive tax audits conducted by tax agencies throughout the country. When these matters cannot be resolved in audit, we litigate state tax cases before administrative tribunals and in state trial and appellate courts. Large companies with multistate operations look to us to develop and manage consistent litigation strategies on a national basis.

Tax planning

Tax planning

Our attorneys drive client value by developing structures that minimize tax exposure. This includes nexus, apportionment and unitary combination planning. We have significant experience designing comprehensive solutions for multistate and multinational companies. We also help clients navigate complex rules for state taxation of inbound and outbound foreign commerce.

Our attorneys drive client value by developing structures that minimize tax exposure. This includes nexus, apportionment and unitary combination planning. We have significant experience designing comprehensive solutions for multistate and multinational companies. We also help clients navigate complex rules for state taxation of inbound and outbound foreign commerce.

We advise clients on merger and acquisition activity to evaluate due diligence, minimize exposure and clear state tax obstacles to closing a transaction. We help clients understand and plan for the state tax implications of changes to their business structure and operations. When noncompliance has been identified, we assist clients in addressing this exposure through voluntary disclosure and amnesty programs.

We advise clients on merger and acquisition activity to evaluate due diligence, minimize exposure and clear state tax obstacles to closing a transaction. We help clients understand and plan for the state tax implications of changes to their business structure and operations. When noncompliance has been identified, we assist clients in addressing this exposure through voluntary disclosure and amnesty programs.

Tax incentives

Tax incentives

State and local tax incentives play a key role in making decisions about investing capital and relocating operations. We assist clients in identifying and negotiating tax incentive programs and ensuring that the legal contracts are structured to protect their benefits and minimize the risk of clawbacks. We have significant experience with data center, headquarters relocation, manufacturing and <a href="https://bakerlawstaging.contentpilot.net/services/community-development/renewable-energy-tax-credits/" target="_blank" rel="noreferrer noopener">renewable energy projects</a>.

State and local tax incentives play a key role in making decisions about investing capital and relocating operations. We assist clients in identifying and negotiating tax incentive programs and ensuring that the legal contracts are structured to protect their benefits and minimize the risk of clawbacks. We have significant experience with data center, headquarters relocation, manufacturing and <a href="https://bakerlawstaging.contentpilot.net/services/community-development/renewable-energy-tax-credits/" target="_blank" rel="noreferrer noopener">renewable energy projects</a>.

Unclaimed property

Unclaimed property

Our attorneys assist clients in defending against <a href="https://bakerlawstaging.contentpilot.net/services/tax/unclaimed-property/" target="_blank" rel="noreferrer noopener">unclaimed property</a> audits, including multistate audits conducted by contingent fee auditors. We also assist companies in establishing policies and procedures to comply with unclaimed property requirements. We help clients manage legal ambiguities with gift cards, tokens, virtual currencies and other digital properties.

Our attorneys assist clients in defending against <a href="https://bakerlawstaging.contentpilot.net/services/tax/unclaimed-property/" target="_blank" rel="noreferrer noopener">unclaimed property</a> audits, including multistate audits conducted by contingent fee auditors. We also assist companies in establishing policies and procedures to comply with unclaimed property requirements. We help clients manage legal ambiguities with gift cards, tokens, virtual currencies and other digital properties.

Policy work

Policy work

We help our clients be proactive in addressing state and local tax issues. This includes negotiating advance letter rulings from state taxing agencies. It also includes working with state legislatures, industry trade groups and other policymakers to ensure that state tax policies align with our clients’ business plans.

We help our clients be proactive in addressing state and local tax issues. This includes negotiating advance letter rulings from state taxing agencies. It also includes working with state legislatures, industry trade groups and other policymakers to ensure that state tax policies align with our clients’ business plans.

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<section class="wp-block-contentpilot-expand-more"><div class="wp-block-contentpilot-expand-more__excerpt is-visible" data-selector="expand-more"></div><div class="wp-block-contentpilot-expand-more__full-content" data-selector="expand-more">Tax controversy and litigationOur attorneys defend companies against aggressive tax audits conducted by tax agencies throughout the country. When these matters cannot be resolved in audit, we litigate state tax cases before administrative tribunals and in state trial and appellate courts. Large companies with multistate operations look to us to develop and manage consistent litigation strategies on a national basis.Tax planningOur attorneys drive client value by developing structures that minimize tax exposure. This includes nexus, apportionment and unitary combination planning. We have significant experience designing comprehensive solutions for multistate and multinational companies. We also help clients navigate complex rules for state taxation of inbound and outbound foreign commerce.We advise clients on merger and acquisition activity to evaluate due diligence, minimize exposure and clear state tax obstacles to closing a transaction. We help clients understand and plan for the state tax implications of changes to their business structure and operations. When noncompliance has been identified, we assist clients in addressing this exposure through voluntary disclosure and amnesty programs.Tax incentivesState and local tax incentives play a key role in making decisions about investing capital and relocating operations. We assist clients in identifying and negotiating tax incentive programs and ensuring that the legal contracts are structured to protect their benefits and minimize the risk of clawbacks. We have significant experience with data center, headquarters relocation, manufacturing and <a href="https://bakerlawstaging.contentpilot.net/services/community-development/renewable-energy-tax-credits/" target="_blank" rel="noreferrer noopener">renewable energy projects</a>.Unclaimed propertyOur attorneys assist clients in defending against <a href="https://bakerlawstaging.contentpilot.net/services/tax/unclaimed-property/" target="_blank" rel="noreferrer noopener">unclaimed property</a> audits, including multistate audits conducted by contingent fee auditors. We also assist companies in establishing policies and procedures to comply with unclaimed property requirements. We help clients manage legal ambiguities with gift cards, tokens, virtual currencies and other digital properties.Policy workWe help our clients be proactive in addressing state and local tax issues. This includes negotiating advance letter rulings from state taxing agencies. It also includes working with state legislatures, industry trade groups and other policymakers to ensure that state tax policies align with our clients’ business plans.</div><button class="wp-block-contentpilot-expand-more__more-button is-visible" data-selector="expand-more">View More</button><button class="wp-block-contentpilot-expand-more__less-button" data-selector="expand-more">View Less</button></section>

Stock Market Numbers showing the graph lines over numbers

Elizabeth Ann Smith (“Betsy”)

Naomi Meisels

Jacqueline S. Best

David D. Ebersole

Matt Hunsaker

Jonathan Drake

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Matt Hunsaker Serves on Panel at Council on State Taxation

Peter Roskam Addresses Expiring Tax Benefits in Agenda Article

Matt Hunsaker Takes Part in 43rd Institute on State and Local Taxation

Michael Semes Lectures at 2024 Philadelphia Tax Summit

Michael Semes Participates in 2024 IPT Credits & Incentives Symposium

John Lehrer, Michael Semes Present at TEI’s 79th Annual Conference

Michael Semes Quoted in Bloomberg Tax Article Regarding Passing of Tax Appeals, Cannabis Fix Bill

Michael Semes Comments on Pennsylvania Hospital Tax Exemption Suit

Matt Hunsaker Provides State Corporate Income Tax Update at COST 55th Annual Meeting

Matt Hunsaker Questions AI Usage and Taxability of Transactions in Law360 Article

Michael Semes Discusses Recent Tax Court Decisions in Tax Notes Article

Michael Semes Teaches Unitary Business Principle at Introduction to State and Local Taxation

Michael Semes Provides Detail on Zilka v. City of Philadelphia Tax Review Board in Law360 Article

Jeff Paravano, Dave Ebersole, Jonathan Drake Present at 2024 Ohio Tax Conference

Mike Semes Authors Article on Pennsylvania’s Proposal to Increase Limit on NOLs

Lead Tax Counsel in Moore v. United States to discuss Federal, State and International Tax Implications of Supreme Court’s Decision

Michael Semes Comments on Pennsylvania’s Proposed Regulation to Define Apportionable Business Income in Law360 Article

Michael Semes Authors Article on California’s NOL Deduction Limit Proposal

BakerHostetler Sponsors Tax Executives Institute Seminar

Mike Semes Presents and Moderates at Second Annual Villanova SALT Forum

Mike Semes Authors Article on Solix Tax Refund Decision for Bloomberg Tax

Mike Semes Comments on Pennsylvania State Tax Reform Efforts in WHYY Article

Mike Semes Cautions California on Taxing Digital Advertising in Bloomberg Article

Eight BakerHostetler Attorneys Named to 2024 Law360 Editorial Advisory Boards

Michael Semes Comments on Pennsylvania Tax Bill SB 1051 in Bloomberg Article

Mike Semes Testifies Before Pennsylvania House Finance Committee

Mike Semes Backs Challenge to Philadelphia’s Tax Credit Policy in Zilka Case

Jeff Paravano, Matt Hunsaker Present at the 2024 TEI Midyear Conference

Ohio Supreme Court Issues Important Municipal Income Tax Decision on Remote Work

Matt Hunsaker Quoted in Law360 Article Examining the Most Influential Tax Cases of 2023

Michael Semes Touts Fairness, Efficiency of Pennsylvania Tax Appeal Plan

Mike Semes Discusses Tangible Personal Property at NYU SALT Institute 2023

Mike Semes Authors Article for Tax Notes Regarding Maine Supreme Judicial Court and Express Scripts

Lehrer and Semes speak at tax credits, incentives symposium

Semes appears on Tax Notes Talk podcast

Semes and Sommer wrap up their analysis of Arizona ADP decision

Semes explains how to build state and local incentives in light of federal and state taxes

Major expansion of PA’s corporate tax base ahead, if bill pending in state Senate passes

Examining the context, impact of Ohio high court tax statute decision

At Texas Comptroller Briefing, Hunsaker explains what’s happening outside the state

Court decision that ‘canned software’ is taxable as tangible personal property raises questions, concerns

Dissenting justices in Michigan tax case accuse majority of allowing ‘money grab’

BakerHostetler team secures favorable Ohio Supreme Court tax ruling for client

Ted Bernert and Dave Ebersole Speak at Annual Ohio Tax Conference

Mike Semes Addresses ‘Astonishing’ Decision in ADP Transaction Privilege Tax Case

Ted Bernert Presents at the Indiana Business Tax Conference

Mike Semes Moderates Judges Panel at State and Local Tax Forum

Michael Semes Comments on Maryland Digital Ad Tax

Six BakerHostetler Attorneys Offer Federal Tax Policy and Controversy Program

Brian Davis and Matt Hunsaker Speak at Tax Executives Institute Conference

Mike Semes Discusses Hot Topics in State and Local Tax

Mike Semes Quoted in Articles on Court Decision to Refund Tax Payments to Synthes

Mike Semes Authors Article on Tax Risks Related to Digital Goods Sales

Remote Work in Transition: Trends and Compliance Considerations

Mike Semes Quoted on Risks to Employers When Employees Secretly Work out of State

Mike Semes Tapped to Join Pennsylvania Governor-Elect Transition Committee

Mike Semes Authors Article on Property Tax Exemption for Wind Farms Credits

Mike Semes Says Advocates of Global Minimum Tax Should Reflect on U.S. Experience

Ohio Supreme Court Waves Red Flag on Commercial Activity Tax Assessment

Ted Bernert Discusses State Taxes and Pass-Through Entities

Mike Semes Discusses State Tax Audits, Administrative Appeals and Adjudications

Matt Hunsaker Offers Out-of-State Update at Texas Comptroller’s Annual Briefing

Matt Hunsaker, Ted Bernert, Mike Semes and Dave Ebersole Speak at COST Mid-West Regional State Tax Seminar

Mike Semes and Dave Ebersole Present Tax Update at Tax Club of Cleveland

Mike Semes Speaks About Proactively Managing Transfer Pricing Risk

Mike Semes Addresses Significance of Court Decision Preventing Pennsylvania from Pursuing Back Taxes from Certain Third-Party Sellers

Ted Bernert Addresses Status of State Taxation of Gain on Sales of Interest in a Business

The State Tax Show

Phasing Out Corporate Income Taxes – North Carolina Edition

Don’t Pick Me! The Multistate Tax Commission Audit Nomination Process

Are Decentralized Sales Tax Regimes Vulnerable to Lawsuits?

You Can Say That, But It Will Cost You – The 1st Amendment and State Taxation

What Lies Beneath – When Does the Sales Tax Manufacturing Exemption Start?

When States Export Their Tax Burden – Washington Bank Surcharge

A 30,000 Foot Look at State Taxation of Corporate Aircraft

State Taxation of Software Part 3 – Software-Related Services

One Simple Trick for Cutting Your State Taxes in Half

Statues, Texas Apportionment (Sirius XM), and Maryland Digital Ad Tax Regs

State Taxation of Software Part 2 – Custom v. Canned Software

Everything About State Taxation of Software – Part 1

More Musings on Digital Advertising Taxes

Sales Tax is Tricky – The Manufacturing Exemption

Bears & California’s SALT Cap Workaround

A Sales Tax Win for SaaS

Data Processing, PL 86-272, and the MTC Partnership Tax Project

Blacklisted! (A Questionable Scheme for State Taxation of Multinationals)

Is Your Company Due a Massachusetts Sales Tax Refund for Software?

NJ Nexus Initiative & Seattle Payroll Tax Update

Dodging the California Foreign Tax Bullet – AB 71

A Step Backwards on Alternative Apportionment – Guest Mike Semes

Did Texas Make It Easier to Get Tax Cases into Court?

What Every Delaware Entity Needs to Know About Unclaimed Property Legislation

The Final Three Fall – Economic Presence & Marketplace Facilitator Tax Law Update

Washington’s New Capital Gains Tax: A Stepping Stone to an Income Tax?

MTC Uniformity Projects: Partnerships & Digital Products

What is Unclaimed Property/Escheat?

Agency Deference in State Tax Cases (and UNO rules)

Sports Betting – States Getting a Piece of the Tax Action

State Transfer Pricing Update: SITAS is Alive, APAs, and Tax Amnesty

The Latest in the World of Property Tax

Federalism Showdown: Does ARPA Prohibit State Tax Cuts?

Services

International Tax

Tax Controversy and Litigation

Transactional Tax

Criminal Tax Defense

Tax-Exempt Organizations and Charitable Giving

State and Local Incentives

Unclaimed Property

State Attorney General Enforcement, Investigations and Litigation

Renewable Energy Tax Credits

<ul>
<li>Litigated Oklahoma apportionment issues for a large media and communications company.</li>
<li>Litigated adjustments made by several states for a Fortune 100 company after a complex Multistate Tax Commission audit.</li>
<li>Assisted a streaming media platform in developing a sales tax compliance program across all states.</li>
<li>Represented a large energy company in connection with an aggressive third-party transfer pricing dispute.</li>
<li>Obtained a full concession of Texas sales and use tax relating to a product warranty/captive insurance structure before trial.</li>
<li>Represented numerous clients in securing tax and non-tax incentives from states and localities, including property, sales and income tax benefits, as well as preferred financing and tax increment financing.</li>
<li>Negotiated a $6.2 million refund of an Ohio use tax for a manufacturer.</li>
<li>Contested property values for a chain of restaurants in various communities for real estate tax purposes.</li>
<li>Defended taxpayers in domicile and residency challenges in New York City as well as in New York state and Ohio.</li>
<li>Litigated a test case for local taxes applicable to senior executives for multiple clients.</li>
<li>Negotiated a $650,000 refund of Ohio income tax related to stock options.</li>
<li>Obtained reductions in manufacturing, printing and public utility facilities for tax purposes.</li>
<li>Represented companies undergoing multistate unclaimed property audits.</li>
<li>Assisted clients with state and local tax issues arising from providing service on a cloud-based platform.</li>
<li>Assisted clients with multistate voluntary disclosure agreements.</li>
</ul>

State and Local Tax

State and Local Tax

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