5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
Kilpatrick’s Jordan Goodman recently presented on the topic of “Apportioning and Situsing for Multistate Direct and Indirect Taxes.” Jordan provides the following key takeaways...more
Welcome to the January 2026 edition of The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. ...more
In Valente Solutions, LLC v. Department of Revenue, the Washington Court of Appeals addressed whether an information technology consulting firm was entitled to a refund of Washington business and occupation (“B&O”) taxes for...more
Chicago SALT Partners David Hughes and Jordan Goodman recently provided a SALT update during their webinar on “Navigating the Complex Landscape of Sales and Use Tax Sourcing” with AGN International. ...more
While most of us with a brother or a sister are used to them tattling to the parents over some perceived slight (real or imagined), it is rare for such squabbles to play out in court. Yet that is exactly what’s happening in...more
On October 22, 2025, a ballot initiative titled the “2026 Billionaire Tax Act” was filed with the California Attorney General. An amendment to the initiative was filed on November 26, 2025....more
This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be the significant taxpayer wins and losses and analyzed those results. Our entire...more
The Professor Paul J. Hartman Memorial State and Local Tax (SALT) Forum, sponsored in conjunction with Vanderbilt University Law School, is a premier event that offers industry professionals, practitioners, and state revenue...more
Like many states, Minnesota uses a market-based approach for calculation of the corporate franchise tax apportionment, by sourcing sales of services to the state where the services are “received.” A recent decision by the...more
Kilpatrick’s Jordan Goodman recently spoke at the Council On State Taxation – 2025 SALT Technology Workshop in the San Francisco Bay Area about the “The Top SALT Taxes Impacting the Technology Sector”. This workshop covered...more
Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more
Like many states, Florida’s corporate income tax regime has special rules applicable to telecommunications companies. The tricky part about taxing the telecommunications industry is how to source receipts earned from...more
Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more
At $13.99 million for 2025, the federal estate tax exclusion is the largest it has ever been, but it will be reduced by half in 2026, which you can read more about in this advisory....more
The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more
Kilpatrick’s David Hughes recently participated in a panel discussion at the 55th Annual Council on State Taxation (COST) Annual Meeting in St. Louis. The session, “Is it Time to Start Apportioning Use Taxes?,” explored...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
On October 4, 2023, Massachusetts Governor Maura Healey signed House Bill 4104 into law. The most significant change it introduces is the adoption of single-sales-factor apportionment (SSF) for all corporate taxpayers, not...more
On April 13, the Massachusetts House of Representatives approved H.3770, a tax reform bill that includes significant changes for individuals, businesses and estates. The bill is now with the Senate’s Ways and Means Committee,...more
The issue of whether receipts from the sale of securities should be included in the franchise tax apportionment factor on a gross or net basis may be heard by the Texas Supreme Court after all. There are two cases, Citgo...more
On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more
A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more
The Illinois Department of Revenue (“IDOR” or “Department”) recently issued a Notice of Proposed Amendment to amend its Regulation (86 Ill. Admin. Code § 100.3200) governing the “throwback” and “throwout” apportionment...more