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State & Local Taxation (SALT)
Wisconsin continues to be ranked highly among the states with the greatest state and local tax burdens. That, coupled with the state’s rigorous practices around auditing and tax collection, highlights the increasing importance business is placing on exceptional state and local taxation counsel and litigation. Whyte Hirschboeck Dudek S.C.’s State & Local Taxation Team offers just that—a strong record of successful outcomes in a wide variety of SALT matters. That includes compliance issues, tax planning and tax refund opportunities, as well as expertise in all levels of audit and appeal.
 
A practice like ours, dedicated specifically to SALT issues, is rare. It allows WHD’S experienced professionals to work tirelessly on the front end—so that state and local tax issues don’t become tax controversy issues or worse, go to litigation. But if litigation is unavoidable, WHD’s expert tax litigators are skilled at helping our clients achieve successful results.
 
WHD’s experience encompasses the following principal areas within SALT planning and litigation:
  • Sales and use
  • Real property
  • License fees
  • Franchise taxes
  • Income taxes
  • Special assessments
  • Impact fees
  • Transfer fees
  • Utility taxes
  • Waste treatment exemption

Our Approach

WHD’s SALT Team is committed to identifying practical solutions for today’s complicated state and local tax issues and aggressively working to keep our clients from putting themselves at risk.
 
In addition to offering a deep and experienced team of counselors and litigators to meet our clients’ special needs, we have formed a unique partnership with one of the nation’s foremost SALT experts, John Healy, MST, CPA and co-editor of “The Multistate Corporate Tax Guide.” His expert insights from a taxpayer perspective enhance the practical business benefits of our services.
 
Our clients also benefit from the firm’s government relations expertise. With a team of seasoned, full-time government affairs professionals—not lawyers with a government affairs specialty—Government Affairs is valuable in advocating for numerous tax and fee issues that affect our clients.

Representative Engagements

  • Client received favorable ruling from Wisconsin Tax Appeals Commission with significance for all taxpayers who use sale-leaseback or similar financing transactions to provide additional capital for operations, etc.
  • Client received favorable ruling from the Wisconsin Court of Appeals against the DOR making their food processing equipment eligible for exemption from property taxation as machinery and equipment used in manufacturing.
  • The Wisconsin Supreme concluded that a client’s activities in Wisconsin did not go beyond the “solicitation of orders,” meaning that the DOR could not assess/collect taxes on client’s net income for a period of six years.
  • The Wisconsin Tax Appeals Commission concluded in the client’s favor that use tax did not apply to tangible personal property the client-taxpayer received by intercompany transfer from separately affiliated entities.
  • The United States Court of Appeals found in favor of the client-municipality concluding that the state statutory remedy for challenging special assessments was adequate.
  • The Wisconsin Court of Appeals concluded that the circuit court properly had subject matter jurisdiction to consider the taxpayer’s appeal of the Department of Revenue’s assessment of additional taxes imposed on our client.

Our Team

The extensive experience of the SALT Team at WHD is the foundation on which our team of skilled legal professionals is built. Our technical expertise and ability extend to the most complex tax issues—ensuring successful, cost-effective outcomes for diverse clients with diverse needs.
 
Because SALT matters involve so many facets, the SALT Team works closely with the firm’s many other practice areas. For every client, we complement the extensive experience and expertise of our team by involving a team of lawyers whose combined expertise matches the client’s unique needs.

Attorneys

Consultants

John C. Healy Consultant Milwaukee jhealy@whdlaw.com

Assistant - Taxation

Jamie L. Schlieckau Assistant - Taxation Milwaukee jschlieckau@whdlaw.com