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State & Local Tax  |  Michigan & Multistate

Michigan State and Local Tax Services That Tell You Exactly Where You Stand

You've grown into new states, hired people who work from anywhere and picked up customers you can't tie to a single address. Somewhere in that growth you created filing obligations no one has quantified. Our Michigan state and local tax advisers help you identify them before an auditor does, along with the refunds and elections most companies leave on the table.

  • Exactly where you've triggered state tax nexus for income, franchise, payroll and sales and use tax;
  • Whether your apportionment and sourcing are quietly overstating what you owe for state income/franchise tax;
  • What your potential exposure is by state, by year and by the various state taxes
Talk to a Michigan SALT Adviser

No cost, no obligation. Simply a 20-minute scoping conversation.

The Problem

Growth Creates State Tax Obligations You Never Signed Up For

Almost no one sets out to become a multistate taxpayer. It happens one hire, one customer and one warehouse at a time. The obligation starts the day the threshold is crossed, not the day you find out.

You hired outside Michigan

A single remote employee can establish income/franchise tax nexus, payroll withholding requirements and a sales tax collection obligation in a new state from Day 1.

Your sales crossed a threshold

Most states now assert nexus on economic activity alone. For example, Michigan's threshold is $350,000 of sourced gross receipts, with no office, property or people physically in the state required.

You use 3PLs or marketplaces

Inventory sitting in a third-party warehouse is your physical presence. Marketplace sales still count toward thresholds even when the platform remits the tax.

You bought or sold a business

Unfiled state returns are the most common surprise in tax due diligence, and successor liability can follow the buyer for years after close.

Your apportionment is on autopilot

Sourcing rules for services and intangibles differ by state and change often. Formulas set years ago routinely overstate or understate creating potential refunds or liabilities for the income/franchise tax today.

A notice just arrived

Nexus questionnaires and audit letters have short clocks. What you say in the first response shapes everything that follows. Talk to state tax professionals before submitting your first response.

What it costs to find out late

There is no statute of limitations on an unfiled return. A state can reach back to the first day you had nexus and assess tax, penalties and interest across every open year. In many states, responsible officers can be held personally liable for uncollected or unremitted sales tax. Exposure that never appears on a balance sheet has a way of appearing in a diligence data room.

Get Tax Planning Help

Michigan at a Glance

The Thresholds That Decide Whether You File in Michigan

$350K

Michigan-sourced gross receipts that create corporate income tax nexus if you actively solicit sales. More than one day of physical presence triggers it on its own.

100%

Michigan apportions the corporate tax base on a single sales factor, which makes sourcing decisions the whole ballgame.

$100K / 200

Prior-year gross sales or separate transactions that trigger sales and use tax registration for remote sellers.

Our Services

State and Local Tax Consulting, Compliance and Controversy

One knowledgeable team across every state you touch, so the nexus answer, the apportionment method and the audit response all align.

State Tax Nexus Studies

A defensible, state-by-state answer to the only question that matters first: where are you actually required to file?

  • Nexus for state income tax, franchise and gross receipts taxes
  • Economic and physical presence review across all 50 states
  • State income tax nexus and sales tax nexus assessed separately, since the thresholds are rarely the same
  • Exposure quantified by year, with a materiality cut-off
  • Voluntary disclosure agreements and amnesty to cap the lookback period

State Tax Apportionment Reviews

Most overpayments/underpayments we find are not exotic. They are historic sourcing rules applied the way they worked five years ago. A short list below for items to consider:

  • State income tax apportionment under single sales factor and market-based sourcing rules
  • Service and intangible revenue sourcing by state
  • Throwback and throwout rule application
  • Alternative apportionment petitions where the statute distorts the activity in the state

Sales and Use Tax Consulting

Taxability is not a setting in your billing system. It is a decision, per product, per state and it needs an owner.

  • Taxability determinations for products, services and software as a service (SaaS)
  • Registration, compliance and exemption certificate management
  • Reverse audits and refund reviews on overpaid use tax
  • Marketplace facilitator and drop-ship analysis

State Tax Audit Defense & Controversy

We take the correspondence, manage the auditor relationship and keep the scope where it belongs.

  • State income tax audit and sales tax audit representation
  • Nexus questionnaire responses drafted before you reply
  • Administrative protests, appeals and penalty abatement
  • Settlement negotiation and closing agreements

Multistate Tax Compliance

Corporate income tax services and filings handled as one coordinated calendar, not numerous disconnected deadlines.

  • State income and franchise tax returns
  • Combined, consolidated and unitary filing analysis
  • Pass-through entity tax (PTET) elections and SALT cap workarounds
  • Financial reporting support, such as state tax provision preparation or review, as well as analysis and documentation of uncertain tax positions
  • Personal property tax returns and consulting
  • Sales, use and gross receipts taxes compliance and consulting

SALT Tax Planning & Transactions

Planning only works if someone raises it before the structure is locked.

  • Entity structuring and legal entity rationalization
  • Buy-side and sell-side state tax due diligence
  • Purchase agreement review and analysis
  • Negotiated and statutory credits and incentives
  • Michigan and multistate incentive capture on expansion

How We Work

A Clear Path from "We're Not Sure" to "We Know"

You should not have to commit to a full engagement to find out whether you have a problem. Here is how our process works:

1 Scope the exposure

We start with a conversation, not a document request list. Where do you sell, where do people work, what moved last year? That is usually enough to tell you whether there is something worth investigating further.

2 Receive a prioritized plan

A written view of your filing obligations by state, the exposure quantified by year, the refund/exposure opportunities we identified and a recommended order of operations with costs attached.

3 Execute and defend

We handle the registrations, voluntary disclosures, amended returns and ongoing compliance, and we are the ones who respond when a state writes back.

Still have questions about your state tax exposure?

Tell us where you operate and we'll tell you whether there's anything worth looking at.

Talk to a SALT Adviser

Who We Work With

Built for Middle-Market Companies with Real Multistate Complexity

Our state and local tax advisory work is a fit for organizations large enough that the exposure is material and lean enough that there is no in-house SALT specialist.

Manufacturers & distributors

Multistate inventory, 3PL networks and exemption certificate exposure across a long customer list.

Transportation & logistics

Fleets crossing state lines, special apportionment rules and mileage-based sourcing that few generalists handle well.

Private equity & portfolio companies

State tax diligence on the way in, exposure clean-up during the hold and a clean data room on the way out.

Real estate & construction

Project-based nexus, contractor use tax and entity structures that span a dozen jurisdictions by design.

Professional & technology services

Market-based sourcing on service revenue, SaaS taxability and a workforce that created nexus the day it went remote.

Investment funds & advisers

State filing obligations that flow through to investors, plus sourcing questions specific to management and incentive fees.

Why Cohen & Co®

National SALT Depth. A Partner Who Answers the Phone.

Most companies in this position are choosing between a national firm that will assign them a manager they never meet, and a local firm that has not handled a 20-state exposure study. That is a false choice.

A dedicated state and local tax practice
Not a generalist tax team that also does SALT. We have specialists whose whole job is nexus, apportionment, sales and use tax, and controversy resolution.
Partner-level leadership, start to finish
The person who scopes your engagement is the person who works it. You will not be handed down after the proposal.
Serious Michigan presence
We opened in downtown Detroit in 2016 and expanded significantly in 2026 with the addition of our Troy office, making Michigan one of our largest markets.
Tax, assurance and advisory under one roof
When the SALT answer changes the audit, valuation or deal, the people who need to know are already in the room.

Where We Are in Michigan

Detroit

1505 Woodward Ave., Suite 200
Detroit, MI 48226
313.424.4871

Troy

1301 W. Long Lake Road, Suite 200
Troy, MI 48098
248.952.0200

National Footprint

15 offices across eight states, and a presence in the Cayman Islands and India through affiliated entities.

Who We Serve

Private companies and their owners, real estate and private equity groups, Fortune 1000 enterprises, and investment firms and funds.

Contact Our Michigan Tax Team

Thinking on State & Local Tax

Whitepaper

2026 Year-End Tax Planning Guide for Private Companies

Planning items to consider, strategies for managing your company's 2026 tax burden, and a checklist to keep you on track with your advisers, including considerations from the One Big Beautiful Bill Act.

Read more

Article

A Partnership's Guide to Recording State and Local Tax Payments

How partnerships can record the three most common types of state and local tax payments: nonresident withholding and composite payments, entity-level expenses, and pass-through entity tax.

Read more

Article

Michigan R&D Tax Credit: Lessons From Year 1 and Why 2026 Planning Starts Now

How the Michigan R&D credit works, how it differs from the federal credit, and what to do now to claim the credit by March 2027.

Read more

Next Step

Find Out Where You Stand Before a State Tells You

A short conversation can often signal whether you have real exposure, a refund opportunity or are on the right track.

1. Tell us where you operate. Fill out the form. It takes about a minute.

2. Talk with a SALT specialist. A 20-minute call with a state and local tax specialist, not a salesperson.

3. Decide with real information. Leave with a point of view on your risk and a starting point to decide if you want, or need, to go further.

Prefer to call? Detroit: 313.424.4871 | Troy: 248.952.0200

Best suited to businesses with roughly $20 million or more in revenue and operations in more than one state.

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FAQ

Frequently Asked Questions

What are SALT services?

SALT services cover every tax a business owes below the federal level: state corporate income and franchise taxes, gross receipts taxes, sales and use tax, personal property tax, and local taxes such as city income tax. The work breaks into four buckets — determining where you are required to file (nexus), calculating how much income each state can tax (apportionment), filing accurately and on time (compliance) and defending those positions when a state challenges them (controversy).

How do I know if my company has state tax nexus in Michigan?

For the Michigan corporate income tax, nexus exists if you have: physical presence in the state for more than one day; you actively solicit sales in Michigan and have $350,000 or more in Michigan-sourced gross receipts; or you hold an ownership interest in a flow-through entity with Michigan nexus. For sales and use tax, a remote seller must register once prior-year gross sales into Michigan exceed $100,000 or 200 separate transactions.

The complication is that these are Michigan's rules only. Every state sets its own, and they rarely match. A nexus study answers the question for all states you touch at once.

Does Michigan have a franchise tax?

Only for financial institutions. Michigan repealed and replaced the Michigan business tax with the corporate income tax, effective January 1, 2012. Under the corporate income tax, most C Corporations pay a corporate income tax on apportioned income, while the remaining Michigan franchise tax applies to financial institutions and is based on total equity capital.

This matters because businesses operating in multiple states often do owe franchise taxes elsewhere — Texas, Delaware, Tennessee and others impose them on bases that have nothing to do with income. A company can be profitable nowhere and still owe franchise tax somewhere.

What is state tax apportionment, and why does it matter so much?

Apportionment is how a multistate business divides its income among the states that can tax it. Michigan and most states now use a single sales factor: the share of your total sales that is sourced to that state determines the share of income it taxes.

That makes sourcing the whole game. For tangible goods it is usually straightforward. For services, software and intangibles it is not. States often disagree on whether to source to where the work was performed, where the benefit was received or where the customer sits. Getting it wrong in either direction is expensive: over-source and you overpay, under-source and you build an assessment.

We just received a state tax audit notice. Can you help?

Yes, and the sooner the better. State tax audit defense is a core part of our practice, and the first response typically sets the scope for everything that follows — which years are examined, which entities are pulled in and whether a nexus questionnaire quietly becomes an assessment.

We take over the correspondence; manage the auditor relationship; prepare your documentation; and handle protests, appeals and penalty abatement if the assessment stands. If you have a notice in hand with a deadline on it, call our Detroit or Troy office directly.

We probably should have been filing in several states. What are our options?

Voluntary disclosure. Most states offer a program that allows an unregistered taxpayer to come forward anonymously, limit the lookback period — typically three to four years instead of an unlimited one — and have penalties waived in exchange for registering and paying the tax and interest.

The key constraint is timing: voluntary disclosure is generally off the table once a state has contacted you. If you suspect exposure, quantifying it and deciding whether to come forward is a conversation worth having now rather than after the notice arrives.

What size company do you typically work with?

Our state and local tax consulting is generally a fit for middle-market organizations. We serve a range of organizations, from manufacturers, distributors and logistics companies from roughly $20 million in revenue upward to $1 billion; to service businesses of similar scale, including private equity portfolio companies, real estate and construction organizations, and investment funds. If you are unsure whether your situation warrants this kind of review, a conversation with us can help.

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