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SALT Scoreboard - Quarter 4, 2024

This is the fourth 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

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...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

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

It’s Not the Eggnog – New Jersey Proposes to Specially Allocate GILTI Based on GDP

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

Overlooked opportunities? State tax considerations relating to investments in federal qualified opportunity zones

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

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