Photo of State and Local Tax
State and Local Tax


State and local governments are becoming increasingly sophisticated and aggressive in their efforts to raise revenue while at the same time creating favorable climates for investment and job creation.  These often-conflicting goals create a challenging and quickly changing tax environment leaving unprepared taxpayers exposed to significant risk of substantial and unplanned costs.

At Sheppard Mullin we approach this multi-state tax environment by being engaged on front-end tax policy and planning as well as after the fact tax controversy.  Whether our clients want to know what is going on before it happens, or a shield in the face of an aggressive and sophisticated tax administrator, Sheppard Mullin has a team of state and local tax experts to assist them. 

Because our state and local tax attorneys operate as a team, our clients can draw from their decades of collective experience that include not only tax planning, administrative and judicial controversy, but also from inside state legislative and administrative agencies.  Our SALT team has extensive experience in a broad array of tax disciplines including sophisticated corporate and personal income tax matters, sales and use taxes (including local allocation), property taxes, unclaimed property, and local business license taxes.  Our SALT team’s broad depth of experience allows Sheppard Mullin to approach client tax matters in a strategic, holistic manner, custom tailoring solutions to achieve client outcomes that are both comprehensive and an efficient utilization of resources.

Comprehensive, Client Focused Services:

Anticipate and Plan:

Our SALT team has extensive experience helping clients navigate the complex state and local tax waters to anticipate, if not avoid, problems before they occur.  Whether involving advanced rulings from state tax agencies or research and advice from Sheppard Mullin’s SALT team, our services reduce uncertainty.  We have deep experience assisting clients with myriad state and local tax matters, helping them avoid pitfalls and seize tax minimization opportunities when dealing with issues such as:

  • State tax nexus
  • Allocation and apportionment of income
  • Business / non-business classification of income
  • Residency and income sourcing for personal income tax purposes
  • Taxability of transactions for sales and use tax purposes
  • California Property tax rules governing complex ‘changes in ownership’
  • Local business license taxes, documentary transfer, and other local taxes

Tax Policy:

Proactively engaging in legislative and regulatory arenas can help ensure your unique circumstances are addressed by policy makers.  Knowing what changes are on the horizon can help you anticipate changing tax environments and possibly avoid future tax controversies.  At Sheppard Mullin, our SALT team has a breadth of experience engaging matters directly in legislative, administrative, and other public policy arenas that assists our clients in navigating the complex waters of state and local tax policy.  Our services, while custom fit to the needs of each client, can include:

  • Customized legislative and regulatory monitoring.
  • Legislative and regulatory engagement, statute and regulation drafting and comment.
  • Direct representation and testimony

Administrative Controversy and Litigation

Anticipating a problem is sometimes only a first step towards ultimate resolution.  Other times, unanticipated circumstances, challenging audit environments, or changing state laws create unexpected exposure that necessitates a robust defense.  At Sheppard Mullin, our SALT team utilizes its experience in working with state and local tax agencies to resolve conflicts quickly and efficiently, whether at audit defense, protest, or settlement.

Nevertheless, sometimes Court is a taxpayer’s only viable forum for dispute resolution and Sheppard Mullin’s team has the experience needed to skillfully represent our clients at every level of state and federal courts.