Anyone here practice SALT? How does it differ from what “regular” tax associates do?

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From my salt class, it seemed more like Con law than tax.

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Yes. We’re considered subject matter experts so part of our work is from other teams, needing hours from us to review their work papers/provision for state specific conformity issues or advise on state specific consulting. We also manage our own clients for provision, consulting work (M&A restructuring, etc.), and do some tax controversy work (usually handled more by the team members with JDs/LLMs since it involves presenting legal memos/arguments.

I thought I was replying in my EY bowl - if you’re at a firm, you’d still be working on other groups deals -like M&A tax components and likely tax controversy. But the stuff about provision work likely doesn’t apply - that more common at tax&accounting firms, not law firms. Sorry for any confusion!

That’s team specific, across different ranks. I’m not sure what you mean by “regular” tax associate.

I am talking about law firm context. By regular tax associate I mean tax lawyers on corporate transactional work or private wealth vs. SALT lawyers that appear more litigation/controversy focused. Is that perception correct? I don’t see much federal controversy work at large law firms but maybe I’m wrong.

I used to work in the tax section for the state AG’s office. Most of the SALT matters I see (other than individual tax) were sales and use tax. I have maybe only seen one corporate income tax case during the time I was there. Like OP said, I think SALT work in law firms is more controversy-focused, and it’s probably different from fed tax enough for one of the law firm job postings that I see to mention “this is not a state tax position.”

I'm a little late here. My practice is exclusively SALT and much of that is controversy work as others have said. I deal mostly with individual income tax but alot of sales tax too. I think SALT involves so much controversy work versus fed tax because the IRS has such low audit rates in recent years while state audit rates are on the rise. From what I see, there's alot of need for our services though sometimes I worry about being pigeonholed.

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