California legislators released bill language addressing Governor Gavin Newsom’s “May Revise” to the state budget that includes the Governor’s so-called “apportionment fix.” If enacted, Assembly Bill 167 and Senate Bill 167...more
On May 10, California Governor Gavin Newsom introduced his “May Revise” of the state budget. In addition to net operating loss deduction suspensions and tax credit usage limitations, one particularly concerning corporate...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
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
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
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