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State tax controversy

Informed preparation and guidance for resolving tax disputes

State tax controversy

Plan and prepare for tax controversy

Businesses have always faced inquiries and audits by state tax authorities, but the rise of online commerce and new IRS initiatives mean audits are becoming more common—and complex. To meet this challenge, you may need outside support from a team specializing in state tax controversy.

As part of the KPMG State and Local Tax practice, our state tax Controversy Service helps companies prepare a detailed audit response and manage the review process as it unfolds. But if a controversy is expected, we help you develop a solid plan for resolving it successfully and efficiently.

Whether you’re dealing with a review from one or multiple states, the KPMG national network of professionals can help address the most difficult issues at every stage, from preplanning to final resolution. Our specialists offer informed advice and insight in key areas including:

  • Identifying and mitigating exposure to audit risk
  • Preparing for an audit and managing an appropriate response
  • Representation and testimony during an appeal

Our SALT Controversy Service is backed by our national State Tax Resource Network, which provides tax professionals selected for their understanding of specific issues and knowledge of state law.


Key state tax controversy support

KPMG can help you manage all types of state tax disputes

When disputes arise, KPMG can serve as a highly qualified intermediary between the tax authorities and your organization. We have the people, knowledge, and resources to guide and support you through any stage of state tax controversy, from reacting to notices to mounting administrative and judicial appeals.




Drawing on our specialists from the KPMG State Tax Resource Network and Washington National Tax practice, we can assist with resolving material assessments, liens, or time-sensitive enforcement actions.



In the event of a state tax audit, our specialists can help manage the process by drafting responses, identifying possible reductions, and negotiating settlements.



If you decide to protest penalties imposed by an audit, we can guide you on developing and drafting arguments and help compile the information needed to support your case.

Administrative appeals and hearings

Administrative appeals and hearings

In appealing a ruling, our specialists can help craft an approach to pursue the greatest possible reduced assessment or the largest refund. We can also represent you during the hearing itself.

Judicial appeals

Judicial appeals

KPMG can assist your legal counsel by providing expert testimony and developing a strategy for settling a case. We can also explain how a settlement may affect future taxes or your tax position in other states.

Our State Tax Resource Network

Our national State Tax Resource Network includes professionals with special skills and experience in technical protest and appeal. Many of them have a background in law or as former employees of state tax agencies. Their procedural knowledge and understanding of how tax agencies operate helps them offer informed guidance on:

  • Strategic audit defense preparation and presentation
  • Informal dispute resolution (IDR) reviews
  • Preparation of persuasive data-supported protests
  • Representation and negotiation at hearings before a hearing officer, law judge, or tribunal.

Our knowledge and experience can help you develop a better-informed strategy for managing state tax disputes as well as lowering assessments. And we can provide guidance on future tax payments.

Strategic guidance

Based on the issues raised by a notice or audit, our professionals can help gather the right data and evidence to counter it effectively.

Reduced assessments

A clear response backed by strong data and a firm understanding of state regulations can lead to significantly reduced assessments or even refunds.

Payment overview

Lessons learned from an audit and response can be applied to plans and processes for future state tax payments.

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Meet our team

Image of Rick Hill
Rick Hill
Partner, State & Local Tax, KPMG US

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