In a prior SALT@Work column for the Journal of Multistate Taxation and Incentives, Eversheds Sutherland attorneys Charlie Kearns and Alexandra Louderback discussed the localization of work rules that determine where an employer will be subject to state unemployment insurance (UI) registration, reporting and taxes when an employee works in multiple states.

Shortly after that

The Illinois Department of Revenue issued a private letter ruling determining that for purposes of the Retailers’ Occupation Tax (“ROT”) and the Services Occupation Tax (“SOT”), a taxpayer that procured marketing materials on behalf of its clients properly sourced these sales to the location of the product manager, the employee responsible for procuring the materials.

On January 6, 2021, the Court of Appeals of New Mexico held that a power purchase agreement (PPA), entered into by a wholesale electricity generator to secure compensation in exchange for providing electricity, constituted intangible property that is not subject to property taxation and cannot be included in the value of the wholesaler’s electric plant

On January 26, the South Carolina Department of Revenue issued Revenue Ruling #21-2, which provides guidance regarding the state’s conformity to Internal Revenue Code (IRC) Section 163(j).

IRC Section 163(j) Background:

  • For tax years beginning before January 1, 2018, IRC Section 163(j) limited business interest expense deductions for certain interest paid or accrued by

The fallout from the Covid-19 health crisis dominated almost every part of New York life in 2020, including New York tax law.

In their column for Bloomberg Tax, Eversheds Sutherland attorneys Michael Hilkin and Chelsea Marmor discuss some of the most important New York legislative and regulatory tax developments to address the pandemic.


As employers look forward to reopening after the COVID-19 pandemic and, perhaps more importantly, adjusting to the “new normal” of indefinite telework, they should evaluate the multistate tax obligations that arise out of remote employees. Some states (and a few localities) have passed laws, promulgated regulations, or issued guidance on the impact that COVID-19 has