introduction

Brian Strahle, EA, MST, CMI, NTPI Fellow. Taxpayer advocate. Multistate Tax Controversy & Risk Management Consultant. Writer. Speaker.

During my 29+ year career, I have written 100+ articles, including my column (The SALT Effect) for Tax Analysts State Tax Notes, and delivered 100+ presentations. As a result, I have developed a process for conducting research and providing guidance to help companies achieve their business objectives in a state tax-efficient manner.

My favorite part of working in the tax field has always been conducting research to answer complex questions and helping clients develop positions and support when the conclusions aren’t quite clear. I also enjoy following the ever-changing world of taxation on a daily basis and writing blog posts, articles, alerts, etc. attempting to explain complex matters in an easy-to-understand format while identifying the issues and potential action steps clients should take.

In 2009, I started writing my blog, "leverage salt," to help businesses and other tax consultants with 'turning the technical into the practical." Today, the blog has over 1,000 posts on a variety of state tax topics (blog posts starting in April 2015 are posted here).

I am a Partner at Frazier & Deeter, LLC where I lead the state and local tax practice. I provide all state tax consulting services through Frazier & Deeter, LLC. All material posted on this site is not affiliated with Frazier & Deeter, LLC and is owned by LEVERAGE SALT, LLC. All views / opinions are mine and do not necessarily represent the views of Frazier & Deeter, LLC.

CONNECT WITH ME ON LINKEDIN

JOIN THE LEVERAGE SALT LINKEDIN GROUP

background

I have 25+ years of tax experience working in public accounting firms (Big 4, national, regional) and industry (Fortune 500 tax departments). My experience encompasses federal and state income tax, franchise tax, gross receipts tax, sales and use tax in almost every state.

My clients have included large C corporation affiliated groups, S corporations, limited liability companies, single-member limited liability companies, Q-subs, and partnerships. I have also helped individual taxpayers with residency audits. In one of my roles, I helped manage state taxation for a large group (over 500 entities) of pass-through entities, so I know the pain of entity-level taxes, non-resident withholding and composite reporting for pass-through entities.

My clients have been in several different industries such as technology (including software-as-a-service, platform-as-a-service, infrastructure-as-a-service), manufacturing, professional services (including technical, financial, advertising, legal, etc.) retail, real estate development and construction, transportation, etc.

At one point in my career, I worked in the national tax office at RSM. That’s when I started doing webinars and seminars. I later started writing my blog, which led to more article writing and my column in Tax Analysts State Tax Notes. As a result, I have a great deal of experience analyzing current developments and transforming them into alerts, articles, whitepapers, presentations and blog posts.

biography

I started my career (in 1995) working at a Fortune 500 manufacturing company managing the state income tax function (provision, planning, compliance, and controversy) for a large consolidated group of companies operating in almost every state. I then added federal tax experience by working at another Fortune 500 company and regional accounting firms. I eventually became the accounting methods and inventory technical leader in the national tax office of RSM.

After gaining in-depth experience on the federal tax side, I ventured back into the state tax area by creating and leading an internal state and local tax group at a national real estate developer/construction contractor. I also served as the state and local tax office leader at Baker Tilly in Minnesota and Washington D.C., and EY in Virginia.

I operated LEVERAGE SALT, LLC as a state tax research, writing and consulting firm from 2013 to 2019. I provided state income tax and sales tax consulting services to Fortune 500 companies and middle market companies. I also worked with Bloomberg and Thomson Reuters to write or review technical material to expand or build out their libraries, served as a subject matter expert to help Bloomberg enhance or build new software tools for state tax compliance and planning, and ghost-wrote articles for accounting and law firms.

Prior to joining Frazier & Deeter, LLC, I led the Tennessee SALT practice of BDO USA, LLP in Nashville from 2019 to 2022.

I hold a Masters of Science in Taxation from the Washington School of Law and a Bachelors of Science in Accounting from Millikin University. I am a Certified Member of the Institute (CMI), a designation obtained from the Institute for Professional in Taxation (IPT) by completing a written and oral exam on sales taxation after achieving multiple years of experience and meeting continuing education requirements. I am also an Enrolled Agent (EA) and a graduate fellow of the National Tax Practice Institute (a three-year CPE program focused on representing taxpayers before the Internal Revenue Service).

sample client results

Identified misapplication of Tennessee franchise/excise tax law and saved the client $3 million on sale of subsidiary.
Reduced Tennessee franchise/excise tax notice from $400,000 to zero due to misapplication of Tennessee franchise/excise tax law to entities in organizational structure.
Reduced potential Tennessee excise tax through proper planning from $20 million to zero on sale of subsidiary.
Saved company $2 million in Tennessee excise tax due to apportionment errors.
Obtained $550,000 sales tax refund related to client's intercompany management fee involving several different types of services in Pennsylvania
Provided practical insight to client as to what positions they should take regarding the sales taxation of cloud computing by conducting 40-state research project and preparing custom matrix
Technical support for client's creation/implementation of a custom sales ‘tax and fee’ engine (40 states)
Multi-year review and analysis of client's sales tax exemption review process (20 states) to determine best practices and provide recommendations whether the client should continue, change or eliminate the current process.
Identified over $1,000,000 in state income tax refund opportunities and $300,000 in prospective annual state income tax savings while conducting a state income tax FIN 48 reserve analysis for a large middle-market company. These refund opportunities were identified in conjunction with the opportunity to utilize Voluntary Disclosure Agreements (VDAs) in multiple states to not only minimize the company's state income tax liability, but also reduce or eliminate the state income tax FIN 48 reserve.
Identified $350,000 in refund opportunities and $100,000 in prospective annual state income tax savings while performing a state income tax nexus look-back review for a middle-market company.
Eliminated $1,200,000 sales tax audit assessment by preparing and filing a written protest with the Minnesota appeals office regarding a "mixed-transaction" or "bundled transaction.”
Obtained $500,000 reduction in sales tax audit assessment after client received a jeopardy assessment from Washington D.C.
Reduced $1 million individual income tax assessment to $20,000 for an individual taxpayer in a Minnesota income tax residency audit
Reduced client's income tax liability by 60% by petitioning and obtaining apportionment relief with Minnesota appeals after audit assessment
Mitigated risk and improved compliance for medical device manufacturer operating in 11 states by researching and providing guidance regarding the sales and use tax taxability of the company’s device
Provided peace of mind to company regarding the sales tax consequences of its Internet/client portal, (“cloud computing”) etc. used to facilitate the delivery of their service
Eliminated $1,300,000 in Washington B&O tax and $1,000,000 in sales tax on 9 real estate projects
Obtained $3,000,000 in Florida Enterprise Zone sales tax refunds on 4 real estate projects
Obtained $1,000,000 in Arizona Transaction Privilege Tax refunds after performing reverse audits on Arizona real estate sales
Obtained $300,000 in California LLC Fee refunds
Reduced annual state income taxes by $500,000 for a $200 million Illinois manufacturer by developing restructuring plan for S corporations and pass-through entities
Identified and obtained a $700,000 refund and annual state tax savings of $150,000 for a $150 million Illinois manufacturer by applying P.L. 86-272
Reduced sales tax audit assessment by $75,000 related to ‘canned vs. custom software’ in Minnesota
Successfully defended a business vs. nonbusiness income position in appeal of a New Mexico income tax audit resulting in tax savings of $300,000, and more importantly, provided support for the position being taken by the company in all states.