State & Local Tax Controversy Case Study www.cbiz.com/saltcontroversy Issue A large manufacturer filed a combined corporate income tax return for its 100 legal entities in New York. A state audit removed approximately 95 of the entities, all of which operated at a loss, on the basis that they did not have New York-based operations. As a result, the manufacturer faced $2.7 million in additional taxes. Solution With the help of our national state and local tax controversy group, the taxpayer protested the assessment. Our team provided documentation that demonstrated the unitary nature of the entities and supported the entities’ proper inclusion in the original combined filing. We took a deep dive into the company, interviewing key personnel and sifting through volumes of information.

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