As businesses expand across state lines and international borders, the tax complexity they carry grows faster than most finance teams recognize. SALT nexus obligations, transfer pricing requirements, and international entity compliance are not areas where general accounting experience is sufficient. The exposure that builds when these are handled inadequately shows up in audits, in transactions, and in the cost of restructuring positions that should have been established correctly from the outset.
What this engagement covers
- Multi-state tax compliance – identifying and managing state and local tax nexus obligations across the jurisdictions where the business has employees, property, or economic presence.
- SALT planning and structuring – building a multi-state tax position that reflects the actual operating footprint of the business and minimizes unnecessary exposure.
- International entity structuring – designing the legal and tax structure for cross-border operations in a way that is compliant, efficient, and aligned with the commercial reality of how the business operates.
- Transfer pricing – establishing and documenting intercompany pricing policies for businesses with related-party transactions across jurisdictions.
- Tax due diligence support – reviewing the tax position of a business ahead of a transaction, identifying historical exposure, and advising on structure to manage risk.
- Compliance catch-up – addressing historical periods where SALT or international obligations were not properly met, and developing a remediation approach that limits ongoing exposure.
Who this is built for
Mid-market businesses that have expanded across state lines or internationally and whose tax compliance has not kept pace with that expansion. Also relevant for businesses entering new markets – US companies moving internationally, or international companies establishing a US presence, where the tax structure needs to be established correctly from the start.
Why does this require specific experience
Multi-state and international tax is not a domain where a generalist CPA brings adequate depth. Krishnan has structured and managed tax compliance across 13 countries in operating roles. The guidance he provides is grounded in how these structures function under real operational pressure, not just how they read in a technical framework.
Engagement model
Project-based for structuring and catch-up work. Ongoing retainer for businesses with continuous multi-state or international compliance requirements.
Situations where this engagement is most relevant
- A business that has hired employees in multiple states and has not assessed the SALT nexus implications of that footprint.
- A technology or e-commerce company with customers or revenue across multiple states and no clear position on economic nexus obligations post-Wayfair.
- A US company establishing operations, a subsidiary, or a distribution arrangement in a foreign jurisdiction for the first time.
- A foreign company entering the US market and needing to structure the entity, the intercompany arrangements, and the US tax position correctly from the outset.
- A business preparing for a transaction where the buyer’s diligence has identified or is likely to identify historical tax exposure.