Multistate Tax Controversy Services

Learn more about our offerings

Deloitte Tax LLP’s Multistate Tax Controversy Services makes available the complete range of services our clients need to prepare for, manage, and effectively resolve state or local tax controversy matters.

Our service offerings include: Proactive resolutions, e.g., engaging in discussions with taxing authorities on an anonymous basis for clients prior to filing returns and, depending on the outcome of the discussions, obtaining written rulings to support the return position; controversy defense, including representing clients in audits, administrative appeals, and settlement negotiations; and information technology and resource solutions to help manage the audit inventory workload efficiently and effectively, from open to close. Since each client-matter is unique, our approach emphasizes a tailored solution, carefully and strategically developed by the appropriate members of our team of controversy and technical specialists.

Proactive resolutions

“An ounce of prevention is worth a pound of cure.”

The most successful result to a potential tax dispute is prevention of the dispute in the first place. Accordingly, our proactive resolution service offerings are structured with an eye for bringing certainty to our clients’ uncertain state tax positions. Through this lens, we help our clients obtain certainty, or at least reduce uncertainty, where it is anticipated that a state tax authority may challenge or dispute a return position. We consider these options with our clients in pre-audit forums, including prior to the filing of a tax return.

Service offerings include:

  • Rulings and advisory opinions
  • Closing agreements
  • Voluntary disclosure agreements
  • Amnesty programs
  • Other administrative dispensation and guidance

Read more about state rulings and apportionment issues.

Meet part of the Deloitte Multistate Tax Controversy network of highly experienced, knowledgeable subject matter specialists

Controversy defense

“The best offense is a good defense.”

Successfully defending a tax return that is being audited, requires careful preparation and advance planning. Yet, for a variety of reasons, many businesses continue to approach audits and tax disputes reactively. We encourage clients to consult a controversy professional as early as possible. Although a state tax audit may seem informal at first, it is a government investigation that deserves careful treatment from the beginning. Our Multistate Tax Controversy Services team has the knowledge and experience to advise you in developing a controversy defense strategy, and to represent you or your company through every phase of the controversy defense process.

  • Controlling the administrative process

A tax controversy often includes scheduling and managing state auditors and tax agency contacts; drafting appropriate and timely responses to information requests; preparing position papers that apply the relevant tax laws to the relevant facts persuasively, yet in a non-confrontational tone; and analyzing settlement scenarios, and negotiating settlements and closing agreements. We understand that each controversy is unique—for example, some are highly dependent on the facts, and some raise legal issues of first impression—and our experienced professionals endeavor to determine that each client’s controversy matter is handled effectively and efficiently.

  • Developing a strategy that can lead to the desired outcome

Our settlement and compromise service offerings are structured to provide a set of value-based alternatives or resolution considerations beyond just the “hazards of litigation” and the resulting cost. Due to their nuanced understanding of the settlement or compromise authority in a client’s jurisdiction and coupled with their deep technical knowledge of the jurisdiction’s litigation strategies, our specialists are well positioned to advise on whether your contested state tax positions are suited for settlement or compromise, appropriate for an administrative decision or order, or ripe for litigation.

  • A holistic approach to defending a state tax assessment

Many state tax controversies present an ideal opportunity for a final look at the tax returns upon which a contested state tax position was presented. This is the time to analyze potential state tax offsets which may reduce or neutralize the state tax assessment and, in certain situations, turn an assessment into a refund. By taking a more broad-based approach to a taxpayer’s state tax controversy instead of narrowly focusing on the issues raised or assessed, our state tax controversy practitioners may identify additional options to reach a more effective resolution.

Read more about Multistate Tax Controversy Services and what your tax auditor knows.

Information technology & resource solutions

Tools for success

We also advise clients regarding their tax examination function and related processes in a value-added, cost-effective manner. We collaborate with the tax team on goal-setting, assist in implementation of efficient audit management processes, and provide management reporting on audit resolution. Services may include contract personnel, controversy management training and support, and using our Tax Controversy Manager tool (also available for licensing) and other state tax amended return technologies.

Read more about Tax Controversy Manager and state tax amended return technologies.

Deloitte Tax’s jurisdictional tax leads

Just as state tax regimes differ across jurisdictions, state administrative procedures and processes also vary. Knowing the procedural options can be critical to efficiently resolving the controversy matter. Deloitte Tax’s Jurisdictional Controversy Leads are experienced in resolving issues with state tax agencies through the available administrative processes.

​Read more about procedural information on five important state tax jurisdictions:



Valerie C. Dickerson
Managing Partner
+1  202 220 2693


Mike Bryan
Managing Director
+1 215 977 7564



Chris Campbell
+1 213 553 3072


Brian Toman
Special Advisor
+1 415 783 6137


Jack Trachtenberg
+1 212 436 4324




Get in touch

Valerie Dickerson

Valerie Dickerson

National Leader | Deloitte Tax LLP

Valerie advises companies regarding state tax posture, state and local tax implications of complex transactions and business restructurings, and tax controversies. In addition to her role as a resourc... More