State and Local Tax Controversy Services 

Our professionals can assist through all levels of a state and local tax audit and controversy—from gathering the facts once your company has been selected for audit to helping resolve the dispute.
We utilize a 50-state managed approach to multistate tax issues to help determine that the position a taxpayer takes in one state is consistent with the laws of the other states where they might also be the subject of an audit. Our phased approach can include:

  • Working with state and local tax auditors to address issues as they arise, evaluating the operative tax law and gathering pertinent facts
  • Analysis of accounting and legal documents* as they relate to the taxpayer’s position
  • Ongoing evaluations of the tax department’s position as it develops
  • Obtaining letter rulings to clarify the tax collector’s position on the taxpayer’s specific facts
  • Tax audit representation, including the critical step of helping to identify potential decreases in tax to offset the issues causing an increase in tax
  • Preparation of administrative claims and refund claims with appropriate documentation (if necessary)
  • Working with state tax departments of revenue to facilitate the possibility of a nonlitigation result
  • Representation at most stages of the administrative process (if necessary)
  • Assistance in the settlement process
  • Assistance with helping clients to take corrective action steps

KPMG LINK Controversy Tracker technology for peace of mind
We understand that tax professionals have a lot on their minds, such as “When does that statute run?” or “When is that refund due?” or “Did I miss that Notice date?”

To help our clients remember these critical dates, KPMG has developed LINK Controversy Tracker, a software application that we use to assist our clients with tracking the important dates surrounding state tax controversies such as statute of limitations, waivers, refund due dates, Information Document Requests (IDRs) and notices.

Voluntary disclosure agreements and state tax amnesty programs
Through the use of a voluntary disclosure agreement (VDA), taxpayers who have failed to file returns and pay state taxes can come forward voluntarily to resolve their tax liabilities.

Our professionals can help you determine when a VDA might be available and beneficial, and can assist with gathering and assembling necessary information. By conducting a thorough review of the facts and circumstances and assisting you in negotiations with the state, we can also help you reach an agreement with the state that potentially limits the total liability by limiting the “look back” period.

Similarly, we can assist in the review and calculation of related tax liabilities along with the preparation of the necessary filings under a state’s amnesty program.

*KPMP LLP (U.S) does not provide legal services.


Nicole Crighton, Partner