“Business-friendly” Texas has been the leading poacher of California-based companies for over a decade, with relocations from tech-dominated California only accelerating during the pandemic. Oddly enough, at a time when Texas’s highest-profile new neighbors are known for cutting-edge research, the state seeks to narrow the scope of its research and development credit applicable to some
Back to the market again! California market-sourcing regulation amendments
In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Associate Annie Rothschild to discuss some noteworthy developments in the proposed amendments to California’s market-sourcing regulations. They highlight changes to the regulations that Annie discusses at length in a recent Tax Notes State article.
They conclude
The California FTB’s proposed market-sourcing regulation: Eight changes to watch
In this installment of A Pinch of SALT for Tax Notes State, Eversheds Sutherland attorneys Eric Coffill and Annie Rothschild review the Franchise Tax Board’s proposed amendments to California’s market-based sourcing regulation, including its conception and eight important changes to watch as it moves through the approval process.
Read the full article here.
MTC SITAS Program addresses Eversheds Sutherland confidentiality concerns and pushes forward with 5 signatory states
On February 2, the Multistate Tax Commission’s State Intercompany Transactions Advisory Service Committee (SITAS) held a public teleconference to address comments provided by Eversheds Sutherland and to schedule the first meeting of those states that have signed on to an Information Sharing Agreement (Agreement).
Eversheds Sutherland submitted a letter to the MTC Executive Committee in
How Justice Breyer influenced state tax jurisprudence
US Supreme Court Justice Stephen Breyer, who announced his retirement last week, leaves behind a series of notable decisions that continue to shape state and local taxation.
In this article published by Law360, Eversheds Sutherland attorneys Jeff Friedman, Justin Brown, Catalina Baron and Cyavash Ahmadi discuss some of Justice Breyer’s notable contributions to the
California doesn’t need GILTI
In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Associate Annie Rothschild for a quick review of GILTI, a 2021 failed California proposal to conform to GILTI and how GILTI has been treated in other states.
They examine the history and purpose of GILTI, and what
2021’s most interesting litigation developments
Courts returned to business in a big way in 2021, following the pandemic-related slowdown in 2020. Over the year, there were several noteworthy income tax and sales tax decisions, as well as two First Amendment cases from the highest courts in Maryland and Ohio that reached opposite results and could be headed to the U.S.
Employer withholding and employee residency
An employee’s state of residency, and in some cases the city and/or county of residency, may significantly affect their employer’s withholding tax obligations. Given the expected increase in permanent remote work, residency complications may exacerbate an employer’s state withholding compliance burdens.
In this SALT@Work column for the November/December issue of Journal of Multistate Taxation and
GILTI and California
Currently, there is no California conformity to GILTI, and GILTI is not part of the tax law in California unless and until the California Legislature adopts it.
In this column for the November/December issue of Journal of Multistate Taxation and Incentives, Eversheds Sutherland attorneys Eric Coffill and Annie Rothschild discuss the California Legislature’s recent
Congress’s preemption of state tax laws is not commandeering
There are several federal statutes that limit state and local taxation, including the Internet Tax Freedom Act and Public Law 86-272. Ever since the U.S. Supreme Court handed down its decision in Murphy v. National Collegiate Athletic Association, there have been calls to apply the “anti-commandeering doctrine” to invalidate or limit these federal laws.