Practice Areas

Communications Transaction Tax

Ryan’s Communications Transaction Tax experts deliver significant tax savings and have improved profitability and cash flow for many of the world’s largest telecommunications companies.

Ryan Expertise

Ryan has provided MetroPCS an outstanding return on investment through a wealth of tax services including sales and use tax, credits and incentives, property tax, and unclaimed property.
Chris Miller Director of Tax client logos_testimonial_metropcs
small_client_representation_metropcs

Find a Ryan Expert

Communications Transaction Tax

Ryan’s Communications Transaction Tax experts represent telecommunications companies, their customers, and industry suppliers. Our clients include traditional wire line operators, wireless providers, satellite phone companies, data centers, Internet providers, cable television companies, Voice over Internet Protocol (VoIP) providers, in addition to many emerging sectors of the industry, and consumers of these types of telecommunications services.

We perform reverse audits that enable our clients to reap sales and use tax savings on purchases of equipment, services, and other expenditures. Our professionals analyze clients’ telecommunications expenditures to determine if they qualify for refunds of overpaid communications transaction taxes. In addition, we assist our clients with innovative credits and incentives services to help minimize operating costs and maximize telecommunications infrastructure investments.

Our industry experts focus on all taxes and fees associated with the telecommunications industry including:

  • Sales and Use Tax
  • Utility Tax
  • Universal Service Fund (USF)
  • Gross Receipts Tax (GRT)
  • Federal Universal Service Fund (FUSF)
  • Federal Excise Tax (FET)
  • Emergency 911 (E911)
  • Various Local Level Taxes, Fees, and Surcharges

Ryan shares knowledge, best practices, and expertise to help clients navigate the myriad of complex gross receipts taxes. The Pennsylvania Gross Receipts Tax, the New York Excise Tax on Telecommunications Services, as well as the Florida Gross Receipts Tax on Communications Services are just some of the numerous municipal gross receipts taxes our clients encounter. The presumption in the past has been that, aside from the obvious deductions and exemptions, all sales and purchases are generally subject to gross receipts taxes in these jurisdictions. However, we have successfully recovered or reduced material amounts of gross receipts taxes and audit assessments by developing tax-saving issues that are not commonly employed in the communications industry.

Ryan’s unique telecommunications tax review service helps both telecommunications companies and customers identify and recover telecommunications tax overpayments. Ryan deploys an industry-leading team of professionals with decades of experience working with these often overlooked and underserviced taxes. Through a comprehensive review process, Ryan can identify, quantify, and recover overpayments in every major taxing jurisdiction. Ryan has successfully assisted clients in audits and reverse audits to reduce their liability for state and local telecommunications excise taxes, E911 taxes and surcharges, Federal Excise Tax (FET), Federal Universal Service Fund (FUSF), state and local universal service funds, infrastructure maintenance fees, and others.

Ryan can add value to your organization by providing statistical studies of voice, Internet, and data traffic patterns for mobile and traditional landline services. We thoroughly analyze your company’s usage data and prepare an evaluation of traffic volume across intrastate, interstate, and international services. Ryan’s seasoned professionals leverage years of specialized experience and industry knowledge to prepare traffic study reports containing information such as:

  • Estimates of call volume of interstate services among all call types
  • Detailed narratives of the methodology used to refine data and prepare estimates
  • Telephone call/data usage matrices
  • Data completeness verification 

Ryan manages the audit process from beginning to end, ensuring that we minimize our client’s burden to the fullest extent possible. Our professionals handle the arduous process of producing records for the state and securing files required to build the case, determining which issues merit an appeal and the likelihood of success for each. We manage the day-to-day information flow between our client and the taxing authority to ensure timely, complete, and accurate responses and assist with accelerated dispute resolution processes to reduce the costs and other burdens associated with audit defense activities. As needed, we meet with auditors, dispute resolution officers, administrative hearings attorneys, and other agents to clearly identify all positions that impact our client’s ability to achieve a favorable outcome.

Services Provided
We understand the importance of constructive relationships with taxing authorities. We also understand that respect is earned. From informal conferences to administrative level appeals, our goal is to resolve tax controversies quickly and professionally. And when disputes can’t be resolved through simple negotiation, we’re prepared to fight for our clients’ interests for as long as it takes. Our Audit Representation provides a comprehensive range of services, including:

  • Audit coordination
  • Audit review and opportunity assessment
  • Audit sampling analysis and evaluation
  • Controversies and appeals
  • Responses for information and document requests
  • Risk assessments
  • Tax audit representation
  • Tax compliance and reporting evaluation
  • Taxability determinations
  • Voluntary disclosure and registration

Ryan’s industry-leading Sampling Analysis and Evaluation service has significant influence on the statistical and non-statistical sampling methods used by many taxing authorities. Our Sampling Analysis and Evaluation professionals work directly with clients on audit sampling issues, as well as support Ryan engagement teams with training and advice, the development of audit sampling plans and evaluations of samples, and preparing and analyzing population data files in preparation of sampling for auditing.

Leveraging years of experience comprehending the structure and methodology of audit examinations, we develop strategic tax reduction techniques that include expanded audit samples, post-audit stratification, and differential analysis, among others. It is our combined knowledge of tax law, audit strategy and methodology, and our emphasis on technical expertise, that help guarantee our representation is unmatched by any other firm.

Services Provided
Ryan provides our clients with solutions for all of their sampling analysis and evaluation needs, including: 

  • Design of audit sampling plans for our clients when the audit population consists of a large number of transactions
  • Development and implementation of alternative sampling and statistical methodologies where state procedures are nonexistent, inadequate, or insufficient for audit sampling purposes
  • Evaluation of audit sampling plans and methodologies proposed by state auditors to ensure that our clients' interests are protected during tax audits
  • Presentations on sampling and statistical methods appropriate for sales and use tax audits to taxpayers, auditors, and professional organizations such as the Institute for Professionals in Taxation (IPT) and the Tax Executives Institute (TEI)
  • Production of a comprehensive report that documents the development of every sampling plan created by the practice for its clients. The documentation process includes archiving all relevant files and databases, and the ability to replicate all random samples if requested by state auditors

Ryan is dedicated to resolving tax disputes expeditiously by assisting clients with controversy resolution and legislative services, as well as protecting the rights of taxpayers through honest and fair public policy. We’re aggressive but professional. We understand the importance of constructive relationships with taxing authorities. We also understand that respect is earned. From informal conferences to administrative level appeals, our goal is to resolve tax controversies quickly and professionally. And when disputes can’t be resolved through simple negotiation, we’re prepared to fight for our clients’ interests for as long as it takes. 

Ryan professionals target every possible tax refund and reduction opportunity for our clients. We commit every day to sifting through, drilling down, and peeling back the intricacies of federal, state, local and international tax to discover truly significant recovery opportunities. And we focus on reducing our clients’ tax liabilities with minimum disruption to their operations, requiring only limited effort from their personnel. 

At Ryan, we are known for our ability to find tax-saving opportunities for our clients and to aggressively fight for those dollars, ensuring that no issue or opportunity for tax minimization is left unrealized. Our professionals rely on expertise, experience, and skilled execution to deliver outstanding value through a suite of tax refund services, including:

  • Audit representation
  • Audit sampling analysis and evaluation
  • Controversies and appeals
  • Filing requirements and documentation
  • Tax research services

Ryan’s Strategic Planning services focus on our client’s overall tax performance, creating greater opportunities to measure and improve efficiency, develop a more strategic approach to tax, and deliver outstanding shareholder value. Through benchmarking current performance, identifying best practices in relation to peer and historical performance, and measuring the delta between reality and the potential of our client’s tax department, Ryan provides a clear strategic plan for transforming the tax function into a Tax Competency Center.

Ryan professionals help our clients plan and implement processes and technologies that improve the efficiency and effectiveness of their tax operations. We assess tax positions and develop strategic plans that include transaction structuring, business reorganization, and alternative filing positions. And we ensure that the efforts of our clients' tax departments are positively impacting the overall strategic objectives of their organizations. 

Services Provided
Ryan leverages years of experience and best practices to help our clients design and implement proven planning strategies for mitigating risk, minimizing tax liabilities, and improving efficiency and effectiveness through a suite of services, including:

  • Alternative filing positions
  • Business reorganization
  • Risk mitigation planning
  • Strategic business planning
  • Tax automation
  • Total performance assessments
  • Transaction structuring
  • Workflow assessments and solutions

Ryan can also add value to your organization by ensuring that you are collecting and remitting the appropriate amount of tax from your customers.  Our industry-specific team of professionals stays up to date with technological advances in the communications industry and the changes in tax laws throughout the country. Whether you are looking to add a new product, enter a new jurisdiction with your current products, ensure when your matrix was last updated, or looking for a sense of security that your matrix is currently up to date, Ryan can provide your company with a diagnostic report detailing what changes should be made along with the appropriate authority if necessary.

www.fcc.gov

www.irs.gov

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.