The principle of nondiscrimination plays a pivotal role in the field of state and local taxation. Discriminatory taxes are said to deter cross-border activity, distort competitive neutrality, and hinder economic efficiency by placing a thumb on the scale of the competitive marketplace. Recognizing these issues, federal and state governments have prohibited discrimination since the founding

In this episode of the SALT Shaker Podcast policy series, Eversheds Sutherland Associate Jeremy Gove takes a turn in the policy hot seat, and interviews Partner Nikki Dobay about her recent article in Tax Notes State, which analyzes two recently enacted measures – Idaho H.B. 677 and New Hampshire H.B. 1097.

Nikki and Jeremy

In this installment of SALT Policy Picks for Tax Notes State, Eversheds Sutherland Partner Nikki Dobay analyzes two recently enacted measures that have fascinated her this legislative session – Idaho H.B. 677 and New Hampshire H.B. 1097. Each is intended to prevent taxation of residents by other states where the activity the other state

Earlier this month, the California Franchise Tax Board released Legal Ruling 2022-02, regarding the sourcing of Internal Revenue Code Section 751(a) gain from the disposition of a nonresident individual’s partnership interest when the IRC Section 751 property is located in California.

In this article for Law360, Eversheds Sutherland Senior Counsel Eric Coffill discusses

Most decisions issued by the California Office of Tax Appeals involve small dollars, but these decisions can still shape precedent.

In this article for Bloomberg Tax, Eversheds Sutherland Senior Counsel Eric Coffill discusses Appeal of R. Sheward, which addresses the Franchise Tax Board’s legal authority to assess tax on unreported income based on

Understanding—let alone navigating—the layers of bureaucracy is no small feat for taxpayers that seek to resolve a California tax controversy, whether through administrative protest and appeals processes or by means of settlement negotiations.

In many states, the counterpart from the department who handles a taxpayer’s protest or appeal also has authority to negotiate a settlement.