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
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
New York state legislators recently introduced legislation loosely proposing to impose a five percent gross receipts tax on data sharing. The legislation says little about how the tax will work, but it has gained the...more
New York Governor Andrew Cuomo released his Fiscal Year 2021 budget and accompanying legislation on January 21, 2020 (the Budget Bill). Consistent with Governor Cuomo’s earlier promises, he has not proposed new taxes other...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 (Department) issued two advisory opinions determining that unauthorized non-life insurance corporations (here, surplus lines insurance companies) are subject to insurance...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
4/26/2016
/ Add-Back Legislation ,
Consolidated Tax Returns ,
Debt ,
Foreign Affiliates ,
Franchise Taxes ,
Income Taxes ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Related Parties ,
State Taxes ,
Tax Deductions ,
U.S. Treasury