In this installment of “A Pinch of SALT,” published by Tax Notes State, Partner Charlie Kearns examines Washington’s newly enacted “millionaire’s tax,” which takes effect in 2028 with returns due in 2029. The law imposes a 9.9% tax on Washington taxable income above $1 million, and introduces rules around residency, sourcing of income, and
In the News
New York’s extension of the primary function test leaves taxpayers buzzing
Bundled and mixed transactions continue to play an ever‑increasing role in New York sales tax determinations, particularly where nontaxable services are sold with software or other taxable property for one nonitemized price.
In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Jeremy Gove and Periklis Fokaidis examine…
NY Tax Talk: Calculating tiered partnership income
Questions around federal conformity and the scope of administrative agency deference continue to shape New York City tax disputes.
In this installment of NY Tax Talk, a quarterly column in Law360 focused on recent developments in New York tax law, Eversheds Sutherland attorneys Liz Cha, Diane Beleckas, and Madison Ball analyze a recent determination of…
Utah porn and ad taxes would boost litigation more than revenue
When states push the limits of tax policy, litigation often follows.
In an article for Bloomberg Tax, Partner Jeff Friedman, along with University of Connecticut School of Law Professor Richard Pomp, examines two Utah proposals – a targeted advertising tax and a tax on online providers of material that is “harmful to minors” –…
Former MTC Executive Director joins Eversheds Sutherland SALT Team
We’re pleased to share that Greg Matson, the former Executive Director of the Multistate Tax Commission (MTC), has joined our SALT team as Counsel.
Greg has decades of experience working on complex state tax issues while representing taxpayers and states. That experience, coupled with his skills as an advocate and advisor, will form the basis…
Using a DJ to KO a bad tax: Expedited challenges to unconstitutional state taxes
In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Jeff Friedman, Charlie Kearns and Charles Capouet examine how declaratory judgment actions can provide an expedited resolution of challenges to state taxes. The authors analyze how courts and legislatures across the country allow – or prohibit – declaratory…
2025’s Most Interesting State Tax (MIST) developments
We’re pleased to share our recap of 2025’s state and local tax highlights, as featured in Tax Notes State.
This year’s Most Interesting State Tax (MIST) developments showcase the expanding scope of state income taxation, new constitutional tests, and the broadening reach of digital goods taxation.
Curious about what’s ahead for SALT in 2026?
ITFA: A federal shield in an expanding digital economy
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…
NY Tax Talk: New ALJs, new rules, apportionment, bundling
The third quarter of 2025 saw notable activity in New York tax law, including new appointments, regulatory changes, and key decisions.
In this installment of NY Tax Talk, a quarterly column in Law360 focused on recent developments in New York tax law, Eversheds Sutherland attorneys Liz Cha and Periklis Fokaidis highlight the filling of ALJ…
An interview with new California FTB Chief Counsel Shane Hofeling
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…



