In this session, Reed Smith lawyers will examine a number of case studies and attempt to explain the parties’ respective reasons for choosing litigation over settlement. Drawing from prior experience representing state revenue departments as general counsel or deputy attorney general, Reed Smith’s lawyers will describe how revenue department official evaluate settlement offers and whether to proceed to trial on a particular issue.

The presenters will also discuss settlement strategies, negotiation techniques, and risk-weighting methods that taxpayers can use to increase their leverage and bargaining power. Case studies will include topics covering net operating losses, intangible addbacks, nexus, and sourcing receipts for apportionment-factor purposes.