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Initially enacted as a temporary measure, Congress made ITFA permanent in 2016 to reflect the enduring federal commitment to preserve a tax-neutral digital infrastructure and protect an evolving digital economy. Indeed, today’s “internet access” is no longer defined by static homepages and email alone, but by cloud computing, digital advertising ecosystems, streaming platforms, and bundled…

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…

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…

In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Charlie Kearns, Cyavash Ahmadi and Constance Chien examine different state approaches to exempting digital inputs, including uniformity efforts in the Streamlined Sales and Use Tax Agreement and under review by the Multistate Tax Commission. They also highlight states…

There is a lot of uncertainty around state tax penalties. The standards are murky because the authority to impose penalties often turns on whether a taxpayer exercised “ordinary business care” or had “reasonable cause” for its tax positions. And while many states use similar standards, courts interpret them differently.

Taxpayers are in a tough spot…

Beginning in 2026, Georgia will have a new judicial branch tax court, replacing the existing Georgia Tax Tribunal, which currently operates within the executive branch.

In this installment of “A Pinch of SALT” published in Tax Notes State, Eversheds Sutherland attorneys Jonathan Feldman, Scott Wright, and Alla Raykin outline the benefits the new Georgia…

For decades, the sales factor has been a primary focus of state and local tax articles and a hot topic of discussion at conferences across the country, and the attention is well deserved. There has been no shortage of impactful legislative changes, interesting administrative rulings, and significant (and at times frustrating) judicial decisions regarding the…