November 2025

This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of significant taxpayer wins and losses and analyzed those results.

This edition includes developments in state and local False Claims Acts, corporate income tax apportionment, and manufacturing exemptions. We also spotlight a couple of recent

In this installment of Across State Lines in Tax Notes State, Eversheds Sutherland Senior Counsel Eric Coffill interviews Shane Hofeling, now chief counsel of the California Franchise Tax Board’s Technical Resources Bureau.

In their conversation, Shane shares insights on his vision for the Legal Division, the evolving role of artificial intelligence at the FTB, collaboration

In this episode of the SALT Shaker Podcast, SALT Counsel Jeremy Gove and Chelsea Marmor dive into the nuanced world of state and local tax penalties.

They explore why penalty abatement standards, such as reasonable cause” and “ordinary care,” remain ambiguous despite the frequent appearance of penalties in tax assessments. With limited statutory and

The Washington Board of Tax Appeals upheld the Department’s determination that certain fees and credits related to mortgage sales to government-sponsored enterprises are included in the lender’s gross income for B&O tax purposes. Specifically, the Board concluded that guaranty fees and loan-level price adjustment fees are part of the lender’s cost of doing business and

On October 24, 2025, the Tennessee Department of Revenue ruled that subscription fees for a mobile heart-health app were subject to sales and use tax. The taxpayer charged an annual flat per-user subscription fee to clients who make subscription offerings available as part of medical benefits to their employees and employees’ dependents. For the subscription

In this episode of the SALT Shaker Podcast, host and SALT Counsel Jeremy Gove sits down with Partner Tim Gustafson to explore the historical evolution and current challenges surrounding California’s sales factor.

The conversation traces California’s apportionment journey from its original equally weighted three-factor formula to today’s dominant single sales factor approach. Jeremy and Tim