In an article for Bloomberg Tax, Eversheds Sutherland attorneys Dan Schlueter and Fahad Mithavayani highlight how Hawaii and Texas are the latest states to join the trend to restrict the discoverability of attorney communications with expert witnesses and what it means for state tax litigation.
In the News
Smooth sailing: MTC begins discussions on the outline for its project on State Taxation of Partnerships
By Nikki Dobay & Catalina Baron on
Posted in In the News
On August 17, 2021, the Multistate Tax Commission (MTC) held its first meeting of the State Taxation of Partnerships Project (the Partnership Project), during which the work group discussed a draft outline of partnership issues. The Partnership Project is being chaired by Laurie McEhatton (California Franchise Tax Board) and staffed by Helen Hecht (General Counsel…
ARPA clawback interim rule — despite Safe Harbor, states fight on
By Nikki Dobay & Jeffrey Friedman on
Posted in In the News
In this installment of SALT Policy Picks for Tax Notes State, Eversheds Sutherland Partners Nikki Dobay and Jeff Friedman explore the interim final rule issued by Treasury regarding state and local government aid provided by the American Rescue Plan Act.
Let’s make a federal case out of it: time to revisit the Tax Injunction Act
By Jeffrey Friedman, Todd Lard & Justin Brown on
Posted in In the News
In their article for the July-August issue of Tax Executive, Eversheds Sutherland attorneys Jeff Friedman, Todd Lard and Justin Brown discuss the Tax Injunction Act (TIA), specifically justifications for modernizing the TIA, including highlighting issues that the TIA has created and the legal and business changes that have taken place since 1937, when Congress…
MTC’s Partner-Ship Tax Project Sets Sail
By Nikki Dobay & Catalina Baron on
Posted in In the News
On June 15, 2021, the Multistate Tax Commission (“MTC”) held its first meeting to discuss the “Project on State Taxation of Partnerships.” The work group intends to focus on the “underdeveloped” state partnership tax rules and provide guidance and structure in the state partnership taxation realm.
During the first meeting, the work group focused on…
SALT Policy Picks: 2021 Q1 legislative overview — what a ride!
By Nikki Dobay on
Posted in In the News, Policy and Legislation
In this installment of SALT Policy Picks for Tax Notes State, Eversheds Sutherland Partner Nikki Dobay reviews state tax bills enacted in the first quarter of 2021, including legislation on sales tax, COVID-19-related issues, and IRC conformity
New York Slice: Executive orders create continued administrative tax appeals deadline confusion
By Michael Hilkin & Jeremy Gove on
Posted in In the News, New York
New York Governor Andrew Cuomo issued a series of executive orders beginning on March 20, 2020, tolling statewide legal filing deadlines from March 20, 2020, to Nov. 3, 2020.
In their column for Bloomberg Tax, Eversheds Sutherland attorneys Michael Hilkin and Jeremy Gove note there is confusion over whether the executive orders apply to…
Application of the Pension Source Law to excess benefit plans
By Charlie Kearns on
In the latest SALT@Work column for the Journal of Multistate Taxation and Incentives, Eversheds Sutherland Partner Charlie Kearns provides an overview of the Pension Source Law, specifically its treatment of excess benefit plans, as well as recent guidance from New York that applies those provisions.
California’s Latest Wealth Tax Proposal: An Overview of AB 310
By Timothy Gustafson & Eric Coffill on
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Appeal of Prince: California Taxation of Nonresident Income From Restricted Stock
By Charlie Kearns & Chelsea Marmor on
State taxation of a nonresident employee’s equity award, such as nonqualified stock options (NQSOs) or restricted stock units (RSUs), has long been a thorn in the side of many tax practitioners, payroll departments, and – of course – employees. In Appeal of Prince, California’s Office of Tax Appeals (OTA) recently addressed the state’s taxation…