November 2025

Meet Luna and Yordy, two lovable rescue pups who have brought plenty of personality (and a little bit of chaos!) to the home of Joe Moore, Vice President, Corporate Tax at Costco.

Luna, a two-year-old white Labrador, is a big, goofy sweetheart who likes to avoid tiny humans at all costs. Her family has learned to

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which state recently sued California alleging that the occasional sale rule applicable for purposes of apportioning corporate income is unconstitutional?

E-mail your response to SALTonline@eversheds-sutherland.com

California adopted UDITPA in 1966, with its equally weighted three-factor formula for apportioning multistate income – property, payroll, and sales. Over time, however, the sales factor has emerged as the primary mechanism for determining tax liability in California.

Today, California’s sales factor is the same as it was nearly 60 years ago. Although the fraction