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
On December 27, 2023, the New York State Department of Taxation and Finance (Department) officially adopted the business corporation franchise tax regulations it submitted to the State Register on August 9, 2023 – marking the...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
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 December 26, 2019, in Matter of Mackenzie Hughes LLP v. New York State Tax Appeals Tribunal, the New York Supreme Court, Appellate Division, held that New York’s retroactive decertification of Qualified Empire Zone...more
1/7/2020
/ Business Taxes ,
Commercial Leases ,
Commercial Real Estate Contracts ,
Decertification ,
Due Process ,
Economic Development ,
Enterprise Zones ,
Limited Liability Partnerships ,
Multi-Factor Test ,
NY Supreme Court ,
Real Estate Development ,
Retroactivity ,
Reversal ,
Tax Appeals ,
Tax Authority ,
Tax Credits ,
Tax Tribunal
On October 31, 2019, the Wisconsin Court of Appeals rejected the Wisconsin Department of Revenue’s (DOR) position in Wisconsin Department of Revenue v. Microsoft Corporation, Case No. 2018AP2024 that Microsoft should “look...more
New York State Governor Andrew Cuomo released his Fiscal Year 2020 budget and accompanying legislation on January 15, 2019 (the Budget Bill). Among other things, the Budget Bill proposes statutory revisions to respond to the...more
1/18/2019
/ Corporate Taxes ,
Dodd-Frank ,
Excise Tax ,
GILTI tax ,
Governor Cuomo ,
Marijuana ,
Online Sales Tax ,
Sales & Use Tax ,
Sales Tax ,
State Budgets ,
Tax Cuts and Jobs Act ,
Tax Exemptions
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
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more
12/26/2018
/ Apportionment ,
Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GDP ,
GILTI tax ,
Governor Murphy ,
Internal Revenue Code (IRC) ,
State and Local Government ,
State Tax Equalization Boards ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Revenues
In a last-minute deal to avert a government shutdown, New Jersey Governor Phil Murphy and the New Jersey Legislature cobbled together a budget with numerous amendments to New Jersey’s tax law. Below is a summary of some of...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
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