MULTISTATE TAX EXPERIENCE
As a former program Specialist for the State of California Franchise Tax Board I have knowledge in all area concerning Multistate Income and Franchise Tax. My 30 years experience dealing with the most sensitive and Large Taxpayers in Los Angeles, place me among the top experts in the area of State taxation for both individual and Corporate taxes in the country.
I have knowledge of the areas that are concentrated on for audit. I understand the area of collections and have insider information of policies and the meaning of policies as they have changed over the years.
Do you understand recent changes in the regulations dealing with apportionment and allocation of income between states. Each state has a different concept.
Do you realize that you have filing requirements in all of the states. These requirements could cost you a pretty penny if you are not aware of them.
Each type of business has different formulas by which they are taxed in indidvual states. for instance if you do business in the motion picture or television area you may not be aware that by simply doing alimited amount of work in a state you may be taxable in a state. The states have programs to identify you and charge you tax. Tax that you are not even aware of. You need someone on your side to determine the correct amount of tax to be paid, if any.
Did you know that you may be eligible for credits that can save you hundreds to millions of taxes by simply knowing and understanding that they exist.
I have knowledge in all areas of State taxation. I have been recognized in the past as having some the greatest expertise in the Entertainment field. I have also a great amount of knowledge in the Financial and investment industries.
Are you or your company prepared for the significant audit issues that have occurred in the area of California Franchise Tax Policies and that of other states in the past several years?
The State of
California and other states around the country have doubled and redoubled their effort to look at State Tax returns in order to determine if there are:
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Abusive Tax Schemes- Despite the fact that your accountants and Lawyers have assured you that the nature of some "Listed transactions" fall fully within the parameters of a substantial transactions. Don't be so sure. The Franchise Tax Board is spending numerous hours looking for such schemes and have adequate personnel to examine the logic behind such transactions and pursue this type of matter. They are cooperating with the IRS and are able to increase your exposure to potential costly examinations and/or assessments. Despite budget shortages large amounts of new auditors ( in
California) are being hired to pursue specifically these types of issues. They have found that these areas produce more potential revenue than other areas of enforcement pursuit.
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Tax Credits- Tax Credits such as R & D Credit and EZ Credits are being looked at rigorously by taxing authorities. Despite elaborate studies that have significant amount of paper and are wrapped up in fancy binders, many of these credits have been thrown out either by the IRS or the California Franchise Tax Board. The analysis contained in these binders is often superficial and is sold to taxpayers by large respectable entities. Clients of large multinational CPA firms have been assured that they are somewhat safe from Audit due to the apparent elaborate analysis contained in these studies. Many companies rely on these studies to insure that the tax risk is limited. This is reflected in their risk analysis. In many cases much more than a "hair cut" has resulted. The internal costs of these audits can be astronomical.
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Apportionment Factors, Allocation of Business vs Non Business entities and Unity: Despite the decrease in focus in these areas in recent years, the probability is high that they will be pursued with new vigor in the upcoming years. Because of the State budget crunch and the retirement of many of the more experienced "baby boomers" agents, a training effort will be made in the area of Apportionment and Allocation of income. The more recent hirees will be focusing on these areas for training purposes. Because of this, many more small to medium sized companies will be examined. In many cases the auditor will lack adequate experience and may make na�ve, time consuming, adjustments. Without adequate knowledge in these areas adjustments that should not have made will go unchallenged.
These are just a few of the problems that may occur due to the increase enforcement in this very specialized area. The economic exposure to companies is often overlooked by large to medium accounting firms. Even when the economic exposure is limited often the time taken in dealing with these examinations strain the limited resources of many (if not most companies) In most cases even the Largest Accounting Firms with Enormous State and Local Tax Departments (SALT) do not have even the generalized expertise to keep up with all of the changes in this areas. They do have some experts in specific areas but they are scattered and not necessarily up to date with current practices.
My name is Gary Kenneth Katz and have had significant experience and understanding of the policies and procedures of the California Franchise Tax Board.
Because of this I have had exposure to other states taxing methods. It is my desire to act as an independent consultant to examine your potential exposure.
I have given significant audit training to executives of several other States' taxing authorities. I have updated them on concepts that apply to all states.