On January 8, 2025, a group of New York State Senators introduced S953, which proposes to increase the gross amount of GILTI under IRC § 951A included in the New York State business income base from 5% to 50%. This increase to corporations’ tax base is done by reducing the amount of GILTI excluded
Another item to check off: New state income tax disclosure requirements
In December 2023, the Financial Accounting Standards Board added significant income tax disclosure requirements to the already cumbersome and complex checklist of state tax financial statement disclosure rules.
In this installment of A Pinch of SALT published in Tax Notes State, Eversheds Sutherland attorneys Todd Betor and Jeff Friedman discuss the Financial Accounting Standards
Virginia Court Sauers on Department of Taxation’s position on electing the manufacturer’s apportionment method
The Court of Appeals of Virginia, upholding the trial court’s decision, held that the successor to The C. F. Sauer Company could elect the manufacturer’s apportionment method for the first time on its amended tax return. By doing so, the court (preliminarily*) paved the way for qualifying taxpayers to take a wait and see approach
A dash of SALT on the deal: Emphasizing SALT in M&A
In this week’s episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove welcomes a fellow New York resident to the show, Partner Todd Betor. Todd recently re-joined the SALT practice in January.
Jeremy and Todd delve into a key area of Todd’s practice, SALT issues arising as a result of mergers, acquisitions, or
A dash of SALT on the deal: Key takeaways from TEI’s 2023 M&A Seminar
State and local tax (SALT) issues may arise from mergers, acquisitions, or dispositions. Eversheds Sutherland Partner Todd Betor presented on Unique State Tax Issues at Tax Executives Institute’s 2023 Mergers & Acquisitions Seminar last week in Nashville, TN.
In addition to the need for SALT advisors to get involved at the outset of a deal
California OTA Finds True Object of Elective Ultrasound is the Pictures of the Baby, Not the Service
In a pending precedential decision, the California Office of Tax Appeals (OTA) held that the true object of a taxpayer’s prenatal imaging business involving elective 3D and 4D ultrasound services is the sale of images captured on tangible medium such as photos, CDs and DVDs. Thus, receipts from such sales are subject to sales
Nebraska Introduces IRC 965/GILTI “Fix” Bill
Since December of 2018, taxpayers have been battling with the Nebraska Department of Revenue over its interpretation of the state’s dividend received deduction (DRD) provisions. Although the statute provides a 100% DRD for dividends or dividends deemed to be received and the Department has long taken the position that Subpart F income qualifies for that
California OTA Tells CDTFA Its Audit Manual Has No Authority In Appeal
In a pending precedential decision, the California Office of Tax Appeals (OTA) held that the California Department of Tax and Fee Administration (CDTFA) is bound to follow its own regulation and could not rely on its audit manual to disregard that regulatory authority. Regulation 1595 provides that the agency will use “book value” as the
Oregon’s Taxation of Railroad’s Intangible Personal Property is Derailed by the 4-R Act
The U.S. Court of Appeals for the Ninth Circuit upheld a rail carrier’s authority to challenge the Oregon Department of Revenue’s taxation of its “accounting goodwill” pursuant to the federal Railroad Revitalization and Regulatory Reform Act, commonly referred to as the 4-R Act.
Oregon imposes tax on real and tangible personal property located in the
SALT Issues in Mergers and Acquisitions
This podcast discusses SALT issues concerning mergers and acquisitions that tax professionals should consider including:
- Tax diligence for buyers
- The impact of tax reform on SALT M&A issues
- State transactional and transfer taxes
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