SALT (State and Local Taxation) Experts

Mercor is connecting exceptional professionals with leading AI research labs developing the next generation of reasoning systems. We are seeking experienced State & Local Tax (SALT) experts to help evaluate, review, and improve AI models' understanding of complex multi-state tax concepts, regulations, and real-world tax planning scenarios.

Analyse and review AI-generated responses involving U.S. state and local tax issues.

Location Requirements

Responsibilities

Requirements

Why Join

Mercor is connecting exceptional professionals with leading AI research labs developing the next generation of reasoning systems. We are seeking experienced State & Local Tax (SALT) experts to help evaluate, review, and improve AI models' understanding of complex multi-state tax concepts, regulations, and real-world tax planning scenarios. Analyse and review AI-generated responses involving U.S. state and local tax issues. Evaluate model performance on multi-state corporate income tax, sales and use tax, and pass-through entity tax scenarios. Create and validate tax research questions, answer keys, and evaluation rubrics. Assess AI reasoning related to: Economic and physical nexus Marketplace facilitator rules P.L. 86-272 protections and limitations State conformity to federal tax law GILTI, Subpart F, §965, and foreign income inclusion issues Apportionment and sourcing methodologies Throwback and throwout rules Combined and unitary reporting Water's-edge elections State tax withholding and mobile workforce rules Digital advertising taxes and emerging SALT developments Identify factual errors, technical inaccuracies, and incomplete legal analysis. Provide written feedback that improves model accuracy and legal-tax reasoning. Review edge cases involving conflicting state rules and evolving administrative guidance. CPA, JD, LLM (Tax), MST, or equivalent advanced tax credential preferred. 5+ years of experience in State & Local Tax (SALT). Experience at a Big 4 firm, national accounting firm, law firm, state revenue department, or corporate tax department strongly preferred. Deep expertise in several of the following: Nexus analysis (economic, physical, factor-presence, and remote employee nexus) P.L. 86-272 State corporate income and franchise taxes Multi-state apportionment and sourcing Combined reporting and unitary business principles Foreign income state taxation (GILTI, Subpart F, §965, NCTI) State conformity and decoupling provisions Sales and use tax compliance Pass-through entity tax (PTET) regimes Nonresident withholding and composite filing requirements State tax controversy, audit defence, or litigation Strong tax research skills using primary authorities, state statutes, regulations, administrative guidance, and case law. Excellent written communication and analytical reasoning skills. Comfortable reviewing nuanced technical tax questions and explaining conclusions clearly. Help shape the next generation of AI systems used for tax research and professional reasoning. Work on intellectually challenging state and local tax issues spanning all major SALT domains. Collaborate with leading AI researchers and tax experts. Opportunity to influence how advanced AI systems understand complex tax law and compliance frameworks. We consider all qualified applicants without regard to legally protected characteristics and provide reasonable accommodations upon request.

• Analyse and review AI-generated responses involving U.S. state and local tax issues.
• Evaluate model performance on multi-state corporate income tax, sales and use tax, and pass-through entity tax scenarios.
• Create and validate tax research questions, answer keys, and evaluation rubrics.
• Assess AI reasoning related to:

Economic and physical nexus

Marketplace facilitator rules

P.L. 86-272 protections and limitations

State conformity to federal tax law

GILTI, Subpart F, §965, and foreign income inclusion issues

Apportionment and sourcing methodologies

Throwback and throwout rules

Combined and unitary reporting

Water's-edge elections

State tax withholding and mobile workforce rules

Digital advertising taxes and emerging SALT developments

• Economic and physical nexus
• Marketplace facilitator rules
• P.L. 86-272 protections and limitations
• State conformity to federal tax law
• GILTI, Subpart F, §965, and foreign income inclusion issues
• Apportionment and sourcing methodologies
• Throwback and throwout rules
• Combined and unitary reporting
• Water's-edge elections
• State tax withholding and mobile workforce rules
• Digital advertising taxes and emerging SALT developments
• Identify factual errors, technical inaccuracies, and incomplete legal analysis.
• Provide written feedback that improves model accuracy and legal-tax reasoning.
• Review edge cases involving conflicting state rules and evolving administrative guidance.
• Economic and physical nexus
• Marketplace facilitator rules
• P.L. 86-272 protections and limitations
• State conformity to federal tax law
• GILTI, Subpart F, §965, and foreign income inclusion issues
• Apportionment and sourcing methodologies
• Throwback and throwout rules
• Combined and unitary reporting
• Water's-edge elections
• State tax withholding and mobile workforce rules
• Digital advertising taxes and emerging SALT developments
• CPA, JD, LLM (Tax), MST, or equivalent advanced tax credential preferred.
• 5+ years of experience in State & Local Tax (SALT).
• Experience at a Big 4 firm, national accounting firm, law firm, state revenue department, or corporate tax department strongly preferred.
• Deep expertise in several of the following:

Nexus analysis (economic, physical, factor-presence, and remote employee nexus)

P.L. 86-272

State corporate income and franchise taxes

Multi-state apportionment and sourcing

Combined reporting and unitary business principles

Foreign income state taxation (GILTI, Subpart F, §965, NCTI)

State conformity and decoupling provisions

Sales and use tax compliance

Pass-through entity tax (PTET) regimes

Nonresident withholding and composite filing requirements

State tax controversy, audit defence, or litigation

• Nexus analysis (economic, physical, factor-presence, and remote employee nexus)
• P.L. 86-272
• State corporate income and franchise taxes
• Multi-state apportionment and sourcing
• Combined reporting and unitary business principles
• Foreign income state taxation (GILTI, Subpart F, §965, NCTI)
• State conformity and decoupling provisions
• Sales and use tax compliance
• Pass-through entity tax (PTET) regimes
• Nonresident withholding and composite filing requirements
• State tax controversy, audit defence, or litigation
• Strong tax research skills using primary authorities, state statutes, regulations, administrative guidance, and case law.
• Excellent written communication and analytical reasoning skills.
• Comfortable reviewing nuanced technical tax questions and explaining conclusions clearly.
• Nexus analysis (economic, physical, factor-presence, and remote employee nexus)
• P.L. 86-272
• State corporate income and franchise taxes
• Multi-state apportionment and sourcing
• Combined reporting and unitary business principles
• Foreign income state taxation (GILTI, Subpart F, §965, NCTI)
• State conformity and decoupling provisions
• Sales and use tax compliance
• Pass-through entity tax (PTET) regimes
• Nonresident withholding and composite filing requirements
• State tax controversy, audit defence, or litigation
• Help shape the next generation of AI systems used for tax research and professional reasoning.
• Work on intellectually challenging state and local tax issues spanning all major SALT domains.
• Collaborate with leading AI researchers and tax experts.
• Opportunity to influence how advanced AI systems understand complex tax law and compliance frameworks.