Exposure Studies
In light of the increased focus by states on auditor training and techniques, audit exposures and potential adjustments are a growing concern of multistate companies. Taxpayers are often unaware that certain tax return positions are red flags for auditors that will produce large assessments. Other tax return positions may require appropriate documentation to overcome an audit challenge. Our comprehensive experience in tax return preparation/review and audit representation/support provides us with unique insight into a taxpayer's potential audit exposures. By performing exposure studies for our clients, we can identify potential audit exposure areas, as well as tax return positions that can be sustained with the right documentation and support. By performing exposure studies, we can also identify nonfiling issues, and determine whether voluntary disclosure can mitigate potential nonfiling assessments for our clients.

• Return Filing Positions
• Nexus and Nonfiling
• Economic Nexus
• Attributional Nexus
• Business Purpose and Economic Substance
• Section 482 Considerations
• FIN 48 Reserve Analysis
• Documentation and Support
• Voluntary Disclosure
• Tax Amnesty

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