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 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
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
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
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
Congress is moving rapidly towards passing the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Extenders Bill) as part of the Consolidated Appropriations Act, 2021. If enacted, the Extenders Bill would extend certain...more
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
On June 26, 2019, the US Supreme Court issued its opinion in Kisor v. Wilkie. The Court declined to overturn Auer v. Robbins and Bowles v. Seminole Rock & Sand Co, but reinforced the limits on the applicability of the...more
6/28/2019
/ Administrative Agencies ,
Ambiguous ,
Appeals ,
Auer Deference ,
Denial of Benefits ,
Judicial Review ,
Kisor v Wilkie ,
Reasonable Interpretations ,
Retroactive Application ,
SCOTUS ,
State Taxes ,
Veterans' Benefits
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
On May 7, 2019, the Internal Revenue Service (IRS) released Notice 2019-33 (Notice) announcing its intention to issue guidance under section 168 of the Internal Revenue Code to clarify the normalization requirements for...more
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...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
On February 28, 2017, the Michigan Department of Treasury (the Department) issued a Notice to Taxpayers (the Notice) explaining its approach in administering the now final Michigan Court of Appeals decision in LaBelle...more
The Michigan Department of Treasury (Department) issued a Notice announcing that it will no longer impose sales or use tax on certain prewritten computer software accessed electronically and associated online services. The...more
The Michigan Supreme Court held that an electric utility’s transmission and distribution equipment used for both taxable and exempt purposes qualifies for a partial sales and use tax exemption. See Detroit Edison Co. v. Dept....more
A day after issuing its decision in Direct Marketing Ass’n v. Brohl, the U.S. Supreme Court decided Alabama Department of Revenue v. CSX Transportation, Inc. The Court held that a rail carrier can show discrimination under...more
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
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
The Streamlined Sales Tax Governing Board (SSTGB), as well as its State and Local Advisory Council (SLAC) and Business Advisory Council (BAC), assembled in Minneapolis this week to discuss a number of policy matters related...more
In this issue:
- California Court of Appeal: No Man May Profit From His Own Wrongdoing in a Court of Justice
- The (True) Object of My Affection: A Nontaxable Stock Screening Service
- Alternate Universe...more
5/1/2013
/ Apportionment ,
Bundling Rules ,
Dividends ,
Equal Protection ,
Equity Compensation ,
Foreclosure ,
Income Taxes ,
Net Investment Income ,
Partnerships ,
Premises Liability ,
Refunds ,
Sales & Use Tax ,
Stocks ,
Voluntary Disclosure Agreement
Originally published in State Tax Notes.
Many states have created special treatment for manufacturers, including tax exemptions, credits, and special income tax apportionment rules. In this edition of A Pinch of SALT, we...more
2/15/2013
/ Apportionment ,
Business Taxes ,
Income Taxes ,
Manufacturers ,
NAICS ,
Occupancy Tax ,
Property Tax ,
Sales & Use Tax ,
State Taxes ,
Tangible Property ,
Tax Credits ,
Tax Incentives