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SALT Scoreboard - Quarter 2, 2024

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

SALT Scoreboard - Quarter 1, 2024

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

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Georgia’s 2024 legislative session: Major tax legislation moving forward

This year’s Georgia’s legislative session is quickly progressing, with some major tax legislation moving towards passage. Last Thursday, February 29, 2024 was “Crossover Day”—the 28th legislative day of 40 total legislative...more

Better than a box of chocolates: Foreign dividends included in California sales factor denominator

On February 14, 2024, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request for rehearing in the Appeal of Microsoft Corporation and Subsidiaries (OTA Case No. 21037336)....more

SALT Scoreboard - Quarter 4, 2023

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

A dash of SALT on the deal: Key takeaways from TEI's 2023 M&A Seminar

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

Florida District Court of Appeals hears oral arguments in addback dispute

​​​​​​​On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more

Maryland’s zombie digital ad tax is not dead

Maryland lawmakers are expected to revive a pair of failed controversial tax expansion proposals shortly after the scheduled start of the next legislative session on January 13, 2021. On May 7, Governor Larry Hogan vetoed...more

Significant tax legislation moves forward in Georgia

Significant state tax legislation will move forward through the Georgia General Assembly. “Crossover Day” was Thursday, March 11 - the 28th legislative day of 40 total legislative days - the day by which all bills must have...more

Return to sender – Chevron deference lives (for the moment)

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

Georgia Legislature enacts significant tax legislation but falls short on major sales tax proposals

Georgia’s 2019 legislative session concluded on April 2, 2019. Several important tax changes passed or were considered this year, and are discussed below. Passed Bills - Unless otherwise indicated, these bills have...more

New York instructs taxpayers on GILTI apportionment

The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as GILTI) for apportionment...more

Georgia Legislature enacts significant income, sales, and property tax legislation

The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation....more

Georgia passes legislation to provide deduction of GILTI from the state tax base

On March 21, 2018, the Georgia Legislature passed SB 328 (the Bill) to exclude IRC § 951A (GILTI ) from Georgia taxable income. The Bill treats GILTI as Subpart F income for purposes of the deduction under OCGA §...more

How will Georgia conform to federal tax reform? Annual legislation introduced

The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted...more

Georgia Senate Special Tax Exemption Study Committee Holds First Meeting 

During the 2017 Legislative Session, Senate Resolution 222 created the Senate Special Tax Exemption Study Committee, which was tasked with examining the “costs and benefits” of all exemptions for Georgia sales and use taxes...more

Maybe Next Season? Georgia Tax Bills Collapse in Last Day of Session

Despite a flurry of last-minute activity at the end of Georgia’s 2017 legislative session, the House and Senate failed to reach a consensus in the final hours on much of the major tax legislation considered during the...more

Here’s the Deal: Georgia Governor Signs Several Significant Tax Bills

Following the conclusion of Georgia’s 2016 legislative session, Governor Nathan Deal signed into law several tax bills touching on a wide range of tax matters, including sales and use taxes, property taxes, corporate income...more

Georgia Keeps It Interesting: Legislature Passes Novel Law on Interest Rates and Refund Claims

On March 24, the Georgia General Assembly passed House Bill 960 (H.B. 960), which would adjust the statutory interest rate applicable to tax assessments and refunds and addresses other issues related to refund claims for...more

Court of Appeals Hears Michigan’s Compact Election Cases

The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more

If They Build It, Will They Come? ALAS Advisory Group Prepares Final Program Design to Present to MTC Executive Committee Amidst...

The Multistate Tax Commission’s (“MTC”) Arm’s-Length Adjustment Services Advisory Group (“the Group”) met via teleconference to continue working on the Final Program Design. States participating on the call were: Alabama,...more

MTC Inches Closer to Developing Its Transfer Pricing Program

The Arm’s Length Adjustment Service Advisory Group (ALAS) of the Multistate Tax Commission (MTC) continued its transfer pricing effort with a teleconference today to discuss its training and implementation program. This...more

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

MTC Executive Committee Advances Significant Part of UDITPA Rewrite

On Thursday, May 8, the Multistate Tax Commission’s (MTC) Executive Committee (Committee) met in Washington, DC. During the meeting the Committee voted to advance its amendments to the Multistate Tax Compact’s (Compact)...more

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