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
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
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 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 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
On October 31, 2019, the Wisconsin Court of Appeals rejected the Wisconsin Department of Revenue’s (DOR) position in Wisconsin Department of Revenue v. Microsoft Corporation, Case No. 2018AP2024 that Microsoft should “look...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
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
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
In a last-minute deal to avert a government shutdown, New Jersey Governor Phil Murphy and the New Jersey Legislature cobbled together a budget with numerous amendments to New Jersey’s tax law. Below is a summary of some of...more
On May 23, 2018, the IRS and the Treasury Department issued Notice 2018-54 announcing their intention to propose regulations addressing the federal tax treatment of state workarounds to the $10,000 ($5,000 in the case of...more
The New York Legislature passed its 2018-2019 Fiscal Year budget on March 30, 2018 (Budget), which is expected to be signed into law by Governor Cuomo. The starting point for determining New York taxable income is federal...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
This morning the U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. By failing to provide a full credit to its residents for taxes paid to other states, Maryland unconstitutionally...more
A divided U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. Comptroller of the Treasury v. Wynne, 575 U.S. __ (2015). The Court affirmed the Maryland Court of Appeals in a 5-4 decision...more