State & Local Tax

The State & Local Tax (SALT) Practice Group at Bass, Berry & Sims has earned a national reputation as the go-to firm for guidance on Tennessee state and local tax issues. Over the last five years, our SALT group has handled more than 70% of all filed cases related to state and local tax disputes. We have represented numerous Fortune 100 and Fortune 500 companies, including General Electric Company, The Home Depot, Inc., Pfizer Inc., J.C. Penney Company, Inc., American Express, Sprint, and many others. The unique strength of our state and local tax attorneys is a product of deep technical knowledge combined with the experience and ardor of our advocacy and negotiation skills.

Our resources are available in either a principal or supplemental capacity. We are prepared to work closely with your staff, regular attorneys, accountants and other advisors in resolving your problems or in planning to minimize future state tax liabilities. We also are able to draw upon our many state contacts to assist you quickly and reasonably.

With offices located across the state of Tennessee, our state and local tax practice is uniquely positioned to advise and represent multi-state businesses on virtually any state and local tax matter, including structural and transactional planning, administrative and judicial resolution of controversies, negotiation of business incentives and legislative initiatives and lobbying. We help our clients navigate a variety of tax laws including:

  • Franchise and excise tax
  • Sales and use tax
  • Business tax
  • Property tax
Representative State & Local Tax Clients

General Electric Company, J.C. Penney Company, Inc., Taco Bell Company, The Limited and related entities, The Home Depot, Inc., Lowes Corporation, SouthTrust Bank, Kellogg Company, Kroger Company, W.R. Grace & Co., Square D Company, Equifax Corporation, Sherwin-Williams Company, Sodexho Marriott Management Company, American General Finance, Ryder Truck, Ticketmaster, Inc., Exel, Inc., Roche Laboratories, GlaxoSmithKline, Pfizer Inc., Medtronic Sofamor Danek, Sprint, York International, Nashua Corporation, Sara Lee Corp., Bank One, SMBC Capital Markets, Conagra, Elan Pharmaceuticals, Allegis Group, L’Oreal, H.J. Heinz, US Smokeless Tobacco Company, Luxottica Retail (Lenscrafters), University of Tennessee, Tate & Lyle Ingredients, Vivendi/Universal Studios, Illinois Tool Works, Vodafone, E.I. Dupont De Nemours & Co., Fifth Third Bank, Qualcomm Incorporated and others.

Areas of Focus

  • Controversy
    • Improper assessments
    • Prosecuting refund claims
    • Unitary combined reporting questions
    • Constitutional limitations on state taxation of interstate commerce
    • Application of sales and use taxes to a variety of software services
    • Handling of net operating losses
    • Proper application of the franchise and excise tax
  • Legislative & Lobbying
    • Monitoring of specific issues and legislative initiatives
    • Preparing legislative proposals
    • Drafting legislation
    • Communicating proposals to the legislative decision-makers
  • Planning
    • Review business operations
    • Legal entity structures
    • Reporting methods
    • Restructuring contemplated acquisitions
  • Relocation
    • Establishing a regional or national headquarters
    • Expanding existing operations in the state
    • Working with local and state economic development personnel
    • Communicating with the Department of Revenue
Michael Cottone
Associate
Robert C. Guth
Senior Tax Attorney
Stephen J. Jasper
Member
Michael D. Sontag
Member