Food & Beverage Manufacturing

The SALT team represents some of the world's largest food and beverage manufacturers who produce anything from meats to cereal, soda, cookies or soup, on a wide variety of state and local tax matters. Issues we address for our food and beverage clients include:

  • The income tax nexus issues resulting from an economic presence in a taxing state due to use of intellectual property in a taxing state by an affiliate
  • Responses to state efforts to forcibly combine food and beverage manufacturers with out-of-state affiliates
  • Ongoing state efforts to increase taxable income through transfer pricing adjustments when products are sold between affiliates
  • Issues arising from an increased use of expense add back adjustments for intercompany payments
  • Interpreting the complex apportionment rules and development of alternative apportionment methods to address the shift from the standard three factor apportionment formula


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