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  • Representing a major beverage manufacturer and distributor in a multistate unclaimed property audit conducted by a contingent fee contract auditor. The auditors’ recommendations would have produced liability in excess of $200 million; settling for $38 million, this matter is among the largest unclaimed property settlements ever.
  • Representing a large health care services provider with a partner base of more than 59 hospitals and more than 10,000 physicians in 15 states in two separate income and franchise tax assessments of more than $25 million by the Mississippi Department of Revenue.
  • Representing a Fortune 100 company in a dispute with the Georgia Department of Revenue involving more than $20 million in various corporate income tax issues. The disputed matters involve (i) jurisdiction issues related to a captive REIT and a captive reinsurance company; (ii) apportionment issues related to an air carrier; (iii) the utilization of various tax credits; and (iv) the constitutionality of the disallowance of certain deductions for expenses paid to affiliates. The appeal is pending with the Georgia Department of Revenue’s Division of Law and Policy.
  • Representing a major health insurance provider in a $44 million dispute over computation of Pennsylvania’s gross premiums tax base involving sourcing of risk.
  • Representing a data processing and disaster recovery company in a $35 million dispute over whether restructuring permits combined filing of returns for New York State and New York City. This matter presents arguments of first impression.
  • Creating and implementing a multistate unclaimed property compliance strategy for one of the world’s largest online travel agencies in connection with various state unclaimed property/escheat audits and assessing the advisability of a voluntary disclosure initiative for non-audit states. Our defense of these audits requires the development of a wide range of legal defenses to unclaimed property liability for different types of property arising out of business-to-business and business-to-consumer transactions.
  • Represented a global vehicle manufacturer in California corporate income tax refund claims related to inclusion of treasury function gross receipts in the sales factor denominator of California’s apportionment formula. After five years spent actively protesting the denial of the client’s refund claims, we negotiated a very favorable settlement using the contours of the formal settlement program, but applying taxpayer-specific interpretations that resulted in a $45 million total refund of tax and interest.