This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2023. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
On February 5, 2024, the Offices of the Controller and Treasurer & Tax Collector for the City and County of San Francisco published a report outlining tax reform recommendations in time to inform a potential ballot measure...more
State and local tax (SALT) issues may arise from mergers, acquisitions, or dispositions. Eversheds Sutherland Partner Todd Betor presented on Unique State Tax Issues at Tax Executives Institute’s 2023 Mergers & Acquisitions...more
Earlier today, the Maryland Senate Budget and Taxation Committee voted to pass out of committee Senate Bill 2, which would impose a new tax on digital advertising services. The committee amended the bill to include a new...more
On February 28, 2020, Maryland’s proposed Digital Advertising Tax was the subject of a hearing by the Maryland House of Delegates’ Ways and Means Committee. House Bill 695 would impose a tax on Maryland gross revenues from...more
New York state legislators recently introduced legislation loosely proposing to impose a five percent gross receipts tax on data sharing. The legislation says little about how the tax will work, but it has gained the...more
On May 20, 2019, the US Supreme Court denied United Parcel Service Inc.’s (UPS) petition in a case which implicates the amount of deference that courts should provide to governmental agencies. Given the importance of...more
In a year that has seen sweeping changes to the state tax landscape brought about by the Tax Cuts and Jobs Act’s (TCJA) revisions to the Internal Revenue Code (I.R.C. or Code), the majority of state tax focus—with good...more
The year 2018 has been a monumental one for the state and local tax community. If the sweeping changes to the US federal tax code made by the federal Tax Cuts and Jobs Act of 2017 (TCJA) and continued efforts by the states to...more
11/2/2018
/ Capital Gains ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
U.S. Treasury
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
4/26/2016
/ Add-Back Legislation ,
Consolidated Tax Returns ,
Debt ,
Foreign Affiliates ,
Franchise Taxes ,
Income Taxes ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Related Parties ,
State Taxes ,
Tax Deductions ,
U.S. Treasury
On February 11, the United States Senate approved a permanent extension of the Internet Tax Freedom Act (ITFA) contained in the Conference Report accompanying H.R. 644, the “Trade Facilitation and Trade Enforcement Act of...more
In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more