Practice Areas

Income Tax

Ryan’s Income Tax professionals have a proven track record of minimizing, managing, defending, and controlling the federal income tax liabilities of many of the world’s largest global corporations.

Income Tax Services

Ryan’s comprehensive Income Tax practice encompasses all aspects of federal, state, and international income tax. The professionals in each of our core income tax practices provide clients with best-in-class service, focusing on minimizing tax liabilities and creating new growth, innovation, and investment opportunities for our clients. We serve as a strategic partner to our clients and efficiently manage all facets of their income tax exposure, including interfacing with local, state, federal, and international tax authorities, providing expert tax opinions, assisting throughout tax controversies, and managing all administrative applications and processes, saving our clients valuable time and resources.

Federal Income Tax Services


Ryan’s Federal Income Tax practice assists clients with solutions that blend the right people, processes, and technology needed to efficiently and effectively manage and control federal income tax liabilities. Our seasoned tax professionals have real-world corporate tax experience to evaluate planned investments and provide expert opinions on possible tax implications, assisting our clients in addressing complicated tax issues with innovative solutions.

We assist clients in all phases of a tax controversy, from meeting with Internal Revenue Service (IRS) and Treasury officials to negotiating on behalf of a client in Appeals. And our proven approach is focused on building a shared vision with our clients, maintaining an open line of communication while aligning resources and delivering high-quality solutions customized to meet their unique needs.

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State Income and Franchise Tax Services


The pressure on corporate tax departments is coming from every direction. State Income and Franchise Tax authorities have become very aggressive and are increasing the frequency and depth of their audits. In addition, state legislators are implementing new statutes or promulgating new rules, most of which are targeted at the elimination of perceived tax “loopholes.”

Ryan can provide tremendous value through technical expertise and best-in-class client service. Whether it is providing assistance with a state income/franchise tax audit, helping your company create and implement a tax-efficient corporate structure, or performing a due diligence review for your acquisition or merger, we focus on finding cost-effective ways to save tax dollars and improve the effectiveness and efficiency of your tax function.

Our comprehensive approach to identifying tax-saving opportunities includes:

  • Analyzing tax calculations, including applicable Federal Income Tax implications
  • Examining alternative or optimal filing methodologies
  • Reviewing formulary apportionment calculations, including alternative apportionment factor methodologies and throwback or throwout calculations

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International Tax Services


Rapid globalization is creating a challenging tax environment as multinational companies continue to expand operations around the world. Complex global operating and supply chain models designed to gain competitive advantage in a new economy only add to the challenges of International Taxation. Additionally, taxing authorities around the world continue to increase their scrutiny of multinational structures and cross-border transactions.

Ryan provides International Tax services like no other firm in the industry. Nearly three fourths of our team’s resources are Principals, Directors, and Managers, which means that our clients realize the value and efficiencies that only come from experience. Innovative strategies, combined with superior implementation processes and flexible pricing methods, ensure that we are unique in our approach. Ryan’s International Tax practice views every engagement, whether it be finding a refund opportunity or tackling compliance, as an opportunity to bring exceptional value to our clients.

Ryan’s International Tax practice has generated millions in savings for clients around the globe by knowing what incentives are available for a specific business and then successfully negotiating the best possible package. Many companies and service providers overlook or are unaware of the numerous programs available. These programs are designed to attract private investment in property and human capital development and vary greatly by state and country. Identifying the incentives for your particular business and determining those that will have the greatest bottom-line impact take enormous time and effort. However, it is an effort that we tirelessly and successfully undertake on behalf of our clients.

A successful incentive package may include credits against tax (i.e., income, franchise, real and personal property, sales and use, withholding); abatements or exemptions of tax; low-interest financing instruments; financial grants; infrastructure development and enhancements; training assistance; and reduction of utility costs. Incentive packages may also be available for capital investments with the upgrade of machinery and equipment or the retention of an existing business and employees.

Most importantly, once an agreement of your incentive package is established with the relevant jurisdictions, we then work with you to ensure that the incentives package is fully administered and that the incentives awarded are actually realized.

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Income Tax Compliance Services


Ryan offers a full suite of income tax compliance services, which encompasses all aspects of federal, state, and international income tax compliance, creating a one-stop shop that saves our clients valuable time and resources. These services include managing costs and employee resources, eliminating manual processes, minimizing overpayments and errors on returns, and reducing risk and the likelihood of notices and penalties. Whether it’s completing a tax form based on information provided or preparing the entire tax return from start to finish, Ryan’s income tax compliance solutions are tailored to fit specific client requirements. Our compliance team serves as a strategic partner alongside clients, focused on finding innovative solutions that reduce tax burden. We view compliance as a critical service offering for our clients, ensuring we drive high value into every tax organization we serve.

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Research and Experimentation (R&E) Tax Credits


Taking full advantage of the R&E tax credit provides permanent cash tax savings to qualified companies. As opposed to research and development (R&D) deductions, R&E tax credits are actual dollar-for-dollar federal and state credits, available to businesses of any size involved in R&E activities. Many companies are not aware of the broad scope of activities that qualify for these credits. Evolving statutes, IRS regulations, and court cases continue to create R&E tax credit opportunities for an ever-widening range of qualified businesses.

The numbers are substantial. R&E tax credits in excess of $9 billion are claimed annually at the federal level alone. Businesses taking full advantage of these credits can recapture up to 20% of increased R&D expenditures. Often, there are additional opportunities to claim credits in years where the statute of limitations are open and obtain significant cash refunds or offset other defined withholdings. Even in circumstances where a client is generating operating losses and cannot currently take advantage of the R&E tax credit at the federal level, the state credit is often still applicable and beneficial. Some states offer refundable credits or other ways to monetize the credit (for example against payroll withholding).

Ryan helps clients navigate the complexities and mitigate the risks of the R&E tax credit, enabling businesses to remain innovative and profitable. With efficient and thorough methodologies that gather in-depth information with minimal disruption to our clients, Ryan accurately executes the three-phase credit process from start to finish at the federal and state levels. We develop and document nexus between qualified activities and costs, even where no accounting exists. We also stratify qualified research expenses (QREs) by risk, so clients can determine their individual risk tolerance.

Transfer Pricing Services


With ever-increasing pressures and a constantly changing tax landscape, many companies are shifting their focus to actively monitor their transfer pricing positions.

Much of our work relates to transfer pricing controversy. We are routinely called upon by both taxpayers, tax authorities, and other parties to assist as expert witnesses in tax litigation and bankruptcy litigation. We negotiate with governments on behalf of our clients.

Our position as industry thought leaders means that large law firms seek us out to assist them, and their clients, in managing some of the largest transfer pricing controversies. We maintain good relationships with tax authorities, and have assisted certain tax authorities in the development of policy positions that allow for “win-win” settlements of large cases and issue types.

Investment Tax Credits


Investment tax credits (ITC) provide valuable incentives for businesses that invest in improvements, primarily related to renewable energy and environmental protections. With an estimated 50% of credits and incentives going unclaimed each year, companies are missing an opportunity to reclaim available funds based on current tax law. One of those missed opportunities is through solar roofing. Ryan can help your business reduce energy costs and qualify for additional tax credits.

Ryan’s team of ITC experts helps businesses understand how to quantify portions of a solar roof system into solar ITC qualification. Our comprehensive service approach also identifies, implements, and coordinates compliance requirements for every project, ensuring that your company utilizes all key opportunities.

Tax Account Analysis Review Program (TAARP)


Ryan TAARP®—our proprietary tax account analysis review program—delivers incredible value and results related to conceptual issues involving interest law, statutes of limitations, claims for refunds, global interest netting, IRS transcription comprehension, and other IRS practice and procedure matters. Our value proposition is simple. We leverage our in-depth knowledge of foundational principles and cutting-edge legal and technical expertise to maximize recoveries, which enhance the effectiveness of our clients’ tax departments.

Ryan’s distinguished TAARP team includes former IRS attorneys and interest analysts who offer unparalleled expertise in securing interest refunds from the IRS and state tax authorities and resolving other tax account-related issues. We have served as expert witnesses, providing technical support in many of the most seminal court cases in this arena, and have testified in front of the United States Congress, IRS, and U.S. Department of the Treasury.

ASC 740 Tax Accounting


With growing complexity in tax law around the world, tax departments are under pressure to provide cost-effective, efficient processes that are accessible, visible, transparent, and adhere to regulatory controls. Ryan’s diligent approach to tax accounting delivers strategic solutions that enable our clients to proactively manage their overall federal, state, and international income tax position. Our global tax team has improved the global reporting process at the world’s largest and most complex multinational organizations. Ryan professionals include former Fortune 100 tax executives who have designed and managed corporate tax accounting matters and associated Sarbanes-Oxley processes and controls. To evaluate client risk and enhance processes, Ryan’s Tax Accounting professionals:

  • Determine and review valuation allowances and admissibility of deferred tax assets
  • Assist with global tax provisioning and tax-basis balance sheet maintenance
  • Identify and measure tax risks and units of accounting impacting the organization
  • Design and implement new processes and systems, tax provision software integration, and training in ASC 740 theory and practice 
  • Provide tax rate/effective tax rate (ETR) analysis and optimization
  • Determine, justify, and document deferred tax accounts
  • Optimize and automate overall tax process
  • Analyze intercompany accounts

Investment Manager Services


Ryan’s comprehensive suite of services identifies tax savings and recovery opportunities that are specific to investment managers. Our team is well-versed in the differing and often complex laws and regulations, which often vary by jurisdiction, to help maximize dividends and to structure your investment strategies for optimal tax efficiency. Ryan’s Investment Manager Services include the following:

  • International Tax Withholding – Ryan’s team of experienced International Tax experts can uncover significant tax recovery opportunities for U.S. regulated investment companies (RICs), pension funds, private funds, and their foreign equivalents. Our team is familiar with the various treaties in place and how to apply that language to recover overwithheld taxes for U.S. investment managers. In addition to our treaty-based recovery approach, Ryan also monitors and pursues global recovery opportunities stemming from legal decisions. We are experts in the identification and adjudication of European Court of Justice Anti-Discrimination claims. By leveraging our global relationships and working in tandem with fund custodians, the Securities and Exchange Commission (SEC), European Commission, and other local tax revenue agencies, Ryan effectively and efficiently helps clients reach a favorable conclusion. Click here to learn more about Ryan’s International Tax Withholding practice.
  • Research and Experimentation Tax Credits – Research and experimentation (R&E) tax credits, which are actual dollar-for-dollar federal and state credits, are broadly available to investment managers. Prior to the commencement of any developmental project involving the improvement or creation of an internal process, these credits must be considered. Ryan’s experienced team can help identify complex R&E credit opportunities and mitigate associated risk, allowing investment managers to make innovative and strategic decisions on future processes and investments. Click here to learn more about Ryan’s R&E Tax Credit Services.
  • Abandoned and Unclaimed Property – Ryan’s integrated Abandoned and Unclaimed Property practice aims to help investment managers identify missed and uncollected dividends they are owed. Tracker® PRO, the world’s most trusted unclaimed and abandoned property compliance software, helps investment managers discover missed dividends and additional capital to further fund their investments. Our clients benefit from our experience navigating the complex abandoned and unclaimed property laws, which vary by jurisdiction. Click here to learn more about Ryan’s Abandoned and Unclaimed Property practice.
  • Ryan Software – Ryan utilizes a suite of innovative proprietary software to help our clients maximize tax savings, reduce their tax burden, and maintain compliance with state, federal, and international tax regulations. Click here to learn more about Ryan’s suite of tax software solutions.

Ryan Expertise

Ryan's Federal team is wonderful to work with, very professional and communicative.
Tax Director Major Business Services Corporation
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Integrated End-to-End Tax Services

Ryan is focused on your overall tax performance—providing innovative solutions to the underlying causes of the errors we identify—and creating greater opportunities to measure and improve your efficiency, develop a more strategic approach to tax, and deliver outstanding value to your shareholders.