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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: 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

Reforming San Francisco’s gross receipts tax

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

DC Tax Revision Commission releases Chairman’s Mark, includes Business Activity Tax and Data Excise Tax

On January 5, 2024, the DC Tax Revision Commission released its “Chairman’s Mark,” which lays out the Commission’s tentative proposals for changes to the District’s tax structure. The Commission released a package of 39...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

Is “The New Normal” in “The Ordinary Course of Business”?

In the midst of the COVID-19 pandemic, we’re repeatedly challenged by “the new normal,” and, as M&A advisors, we’ve wondered, “is ‘the new normal’ in ‘the ordinary course of business’”? ...more

Social distancing: When states decouple from the federal CARES Act

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

2020 is hereby incorporated by reference - Maximizing deal value through thoughtful disclosure

When the last of the cool spring days are behind us, stay-at-home orders are lifted, and M&A activity begins to resume in earnest, the high of the seemingly unending “seller’s market” of the past few years may very likely...more

New York Senate introduces digital advertising tax bill

On March 13, 2020, New York State Senator and Deputy Majority Leader Michael Gianaris (Democrat) introduced New York S.8056, which would establish a tax on a digital advertiser’s annual gross revenues derived from digital...more

Maryland’s digital advertising tax bill passes out of committee with amendments

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

Maryland hearing on Digital Advertising Tax highlights problems, hints at amendments  

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

Tax on digital advertising introduced in Maryland Senate, hon

Maryland State Senators Miller and Ferguson have introduced legislation (Senate Bill 2) that would impose a new Digital Advertising Gross Revenues Tax for all taxable years beginning after December 31, 2020. If signed into...more

Illinois Appellate Court Upholds Chicago Streaming Tax

On September 30, 2019, in Labell v. City of Chicago, the Illinois Appellate Court upheld the City of Chicago’s imposition of its amusement tax on streaming video, streaming audio and online gaming services. Background -...more

Taxation without a DC location – the District of Columbia’s Universal Paid Leave Act tax goes into effect July 1, 2019

In order to support the District of Columbia’s new Universal Paid Leave Act (the Act), covered employers will be required to contribute to the Universal Paid Leave Implementation Fund (the Fund), by way of a payroll tax of...more

Maryland bill proposes digital goods tax

The Maryland House of Delegates is considering legislation (House Bill 426) that would impose sales and use tax on digital products and sales tax on digital codes. If signed into law, Maryland would begin taxing digital...more

Missouri bill would require payment processors to collect sales tax

The Missouri House of Representatives is considering legislation (House Bill 648) that would impose sales tax collection obligations on payment processors. House Bill 648 was introduced on January 23, 2019, was read in the...more

New York Governor proposes significant tax changes

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

DC QHTC regulation amended to require new application procedure

The District provides a variety of tax benefits to QHTCs, including sales and use tax and personal property tax exemptions, as well as a reduced corporation franchise tax rate. In order to qualify as a QHTC, a business must:...more

District of Columbia imposes Wayfair nexus standard, digital goods taxation and marketplace sales tax collection requirements

On December 31, 2018, District of Columbia Mayor Muriel Bowser signed B22-1070, the Internet Sales Tax Emergency Amendment Act of 2018 (Emergency Act). As of January 1, 2019, the District of Columbia now subjects digital...more

Thanksgiving dinner arrives early – New Jersey serves up some amnesty dessert with some penalty turkey

New Jersey launched its tax Amnesty program on November 15, 2018. The program runs through January 15, 2019. Here are the top things you need to know about the program...more

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