Led by a former Texas franchise tax auditor and former state tax partner at a large CPA firm.
Businesses facing a Texas Comptroller audit need someone with strong technical knowledge — not generic SALT support. Every project at State Tax Resources is led by a practitioner with deep experience on both sides of the franchise tax audit process.
Preparing for a Texas Franchise Tax audit requires a systematic approach. This includes reviewing your initial notice, organizing your records for a 4-year lookback period, validating your COGS or compensation deductions, and auditing your apportionment calculations. Review our comprehensive pre-audit checklist below, which has been developed and structured by a former Texas Franchise Tax auditor.
Texas Franchise Tax Audit Guide: A Pre-audit Checklist
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Don’t Panic: There is no reason to panic but it is very important to not ignore the notice. An audit could have been generated on your company for a number of different reasons but that does not automatically mean that you will end up owing additional tax. There are some situations where you might even be entitled to a refund.
Read the Notice to Verify the Audit Period: Texas has a 4-year statute of limitations so the audits normally cover 4 years.
Respond Timely: Missing the requested return due date could cause increased scrutiny.
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All Public Information Reports (PIR) or Ownership Information Reports (OIR)
All original franchise tax reports and supporting workpaper including apportionment schedules
Copies of Federal Income Tax returns for each year under audit. (Note: Texas refers to report years rather than normal tax years. For example, the 2026 franchise tax report is based on the taxpayer’s 2025 activity.)
General ledgers and trial balances
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Cost of Goods Sold (COGS): If COGS was used, review the Comptroller’s guidance and Rule 3.588 to confirm qualification for this method and ensure costs used in the COGS deduction were calculated correctly. Follow this link (Franchise Tax COGS FAQ) for the Comptroller’s FAQ’s on COGS.
Compensation Deduction: If the compensation deduction was used, review the Comptroller’s guidance in Rule 3.589 to make sure all qualifying compensation expenses were included and that there were no deductions above the applicable compensation limit for each year. See the Comptroller’s FAQ’s on the compensation deduction for more information.
Apportionment: Review apportionment schedules to confirm the calculation is correct and consider special rules for services and certain industries. See Rule 3.591 for more detailed information.
Reduced Tax Rate: Taxpayers primarily engaged in retail or wholesale trade can use a reduced tax rate. The qualification to use the reduced tax rate has been expanded to include certain types of rental companies. However, some other changes make it more difficult to qualify for the reduced rate for companies that use third parties to manufacture their products. See Rule 3.584 for additional information.
Combined reporting: Combined reporting is required for members of a group that meet the ownership requirements and meet the Texas definition of a unitary business. See the Comptroller’s FAQ’s on combined reporting and the relevant rule (Rule 3.594).Description text goes here
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Appoint a single point of contact.
Make sure a Power of Attorney is completed for anyone outside the company that may need to interact with the auditor.
Ask the auditor to direct all questions to the single point of contact and also ask employees within the company to defer to the point of contact if the auditor asks them any questions.
Respond as quickly as possible to requests from the auditor. It is preferable that you are waiting on the auditor rather than the auditor waiting on you.
Remember that auditors are people too!! Be respectful and helpful to the auditors and you will have a better audit experience. Auditors meet regularly with their supervisors and one topic is aged audits. Auditors want to close the audit as quickly as you do.Item description
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Taxpayers generally deal with a Texas franchise tax audit once every four years. Experienced state & local tax professionals often have handled hundreds of franchise tax audits for clients.
It is not unusual for taxpayers to turn to their tax compliance firm but make sure that firm has someone with significant experience with Texas franchise tax audits. Companies often select a firm for tax compliance based on the lowest fee which does not give that firm much flexibility to research issues and consider alternative filing positions. You do not have to use your tax compliance firm for franchise tax audit assistance. It is often good to have someone else take a fresh look at your returns.
Texas audit notices are public record which results in some firms aggressively calling companies under audit. Consider evaluating several experienced firms rather than going with the first firm that calls you.
Need Help Preparing for Your Audit?
If you have received a notice or want an expert, independent review of your filings before the auditor arrives, let's talk.
John.laborde@statetaxresources.com
Phone: 713-367-1932
https://www.statetaxresources.com/
Why Businesses Choose State Tax Resources
Extensive Texas Franchise Tax Audit Experience
Many years of experience providing Texas franchise tax audit assistance, including pre‑audit planning, document organization, and representation throughout the audit.
Technical Expertise That Stands Up to Audit Scrutiny
Strong understanding of federal income tax concepts that affect the franchise tax
Extensive experience analyzing cost of goods sold (COGS) to support eligibility, maximize deductions, and defend positions during Texas Comptroller audits
Deep understanding of Texas apportionment rules, including policy changes, sourcing of service revenue, and audit impacts across multiple periods
Authority on Texas Franchise Tax Law and Policy
Strong knowledge of how court cases, Comptroller hearings, and policy updates affect the franchise tax calculation and audit outcomes
Experience supporting refund positions involving industry‑specific revenue exclusions
Combined Reporting and Complex Structures
Significant experience with combined reporting, including affiliate inclusions/exclusions, unitary determinations, and intercompany eliminations
Audit Defense and Issue Resolution
Extensive experience addressing common audit adjustments made by Texas Comptroller auditors — and how to challenge them effectively
Strong track record resolving audit issues, representing clients during Independent Audit Reviews (IARs), and managing the redetermination process
Introductions to Trusted Tax Attorneys When Needed
Established relationships with Texas tax attorneys for matters requiring legal representation, ensuring seamless referrals
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Get guidance from a former Texas Comptroller auditor with deep technical experience in franchise tax audits, refund claims, and audit defense.