State and local taxing regimes are enormously complex, widely varying and ever-changing. Because they often lack clear guidance on how they should be applied, they create uncertainties that pose challenges for both taxpayers and tax administrators alike. The uncertainties for multistate taxpayers are quickly compounded, given the thousands of state and local taxing jurisdictions in the United States.
When the law is unclear, most taxpayers do their best to reasonably interpret the law. Such an approach is generally acceptable because state and local tax authorities are equipped with mechanisms, grounded in principles of sound tax policy, to ensure that state and local tax laws are properly enforced. History has shown that those mechanisms are effective in resolving tax disputes without compromising sound tax policy.
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