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 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
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
The CARES Act provides for special federal tax treatment for “coronavirus-related distributions” from most types of tax-qualified retirement plans and IRAs. The distribution must be made between January 1, 2020 and December...more
Approximately 9 months after its issuance, the New Jersey Division of Taxation released a statement retracting Technical Bulletin TB-85, which provided a bizarre method to attribute to New Jersey Global Intangible Low-Taxed...more
In a significant reversal of prior policy, on June 20, 2019, the New York State Assembly and New York State Senate passed Senate Bill 6615, which will exclude 95% of a corporate franchise taxpayer’s gross global intangible...more
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 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
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
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
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
In this issue:
- No Expressions of Goodwill from Arizona Department of Revenue
- California Court of Appeal: ITFA Doesn’t Make the CUT
- Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual...more
In this issue:
- Arizona: Software Licenses Determined to Be Personal Property Rentals
- Rent-a-Cloud: Arizona’s Transaction Privilege Tax Applies to Receipts from the Temporary Use of Online Software
-...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
In this issue:
- Delivered by Independent Contractors, Undelivered by P.L. 86-272: Order Fulfillment Activities Subject Out-of-State Seller to New York Corporation Franchise Tax
- Everything’s Bigger in Texas,...more