Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: By what percentage did Louisiana lawmakers vote to increase the state tax rate on online sports betting?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which recently-signed bill in Iowa expanded property tax and sales and use tax breaks for data centers to include leased facilities?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

SALT Partner Charlie Kearns is pleased to speak during the Institute for Professionals in Taxation 49th Annual Conference, held June 22-25, 2025 in Fort Lauderdale, FL. His session will explore the types of internal agency guidance used in sales and use tax enforcement, how they influence audit outcomes, and the legal and procedural challenges they present. Charlie and his co-panelists will offer practical insights on identifying when such guidance is being used, understanding its impact, and developing strategies to effectively respond or challenge its application in audits and appeals.

For more information and to register, click here.

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which individuals or entities does Nebraska permit to claim a tax credit against their income tax liability for 5% of the compensation paid to employees in the state?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

The New York Division of Tax Appeals determined that the taxpayer’s sale of a document management services was a taxable sale of software. While the taxpayer argued that its service was a nontaxable, cloud-based platform-as-a-service, the ALJ disagreed. Instead, the ALJ concluded that the taxpayer’s software was the “core element” of the platform, and customers could do nothing with the platform without their use of the taxpayer’s software. Therefore, the ALJ determined that because software was the central element of the product, the customer was purchasing taxable prewritten computer software rather than a nontaxable service. 

NetVoyage Corp. aka NetDocuments.com, DTA No. 850246 (N.Y. Div. of Tax App. Apr. 24, 2025).

The Tax Appeals Tribunal upheld an ALJ’s determination that a taxpayer’s wages earned from working remotely in Connecticut were sourced to New York and subject to tax. For decades, New York has adopted the convenience of the employer test (Rule), which deems a nonresident who teleworks outside the state to be working at its employer’s New York location (and, hence, such wages would be New York-sourced), unless the nonresident teleworks out of necessity for the employer and not just for the employee’s convenience.

During the COVID-19 pandemic, the taxpayer, Professor Zelinsky, was required to telework from his home in Connecticut because New York issued an executive order requiring non-essential workers to telework and because his employer prohibited access to his New York office. The Tribunal held that even though Professor Zelinsky did not work in New York, he had sufficient minimal contacts with the state to satisfy due process. The Tribunal reasoned that the professor availed himself of the state’s economic market through his New York-based employer, even though he spent less than 10% of his total working days in the state. The Tribunal also held that the Rule did not violate the dormant Commerce Clause because if the Rule was applied in every state, double taxation would be avoided, and the Rule only taxes wages from activities performed in the state.

Matter of Zelinsky, DTA Nos. 830517 & 830681 (N.Y.S. Tax App. Trib. May 15, 2025).

This is Professor Zelinsky’s second attempt to take down the Rule. See Zelinsky v. Tax Appeals Tribunal, 1 N.Y.3d 85 (N.Y. 2003), cert. denied, 541 U.S. 1009 (2004).

For decades, the NYU School of Professional Studies has offered a host of Tax Conferences that explore foundational and advanced tax topics.

The Eversheds Sutherland SALT team is proud to chair this year’s Introduction to State and Local Taxation and Intermediate State and Local Taxation conferences, featuring updated content, speakers and timely insights.

Introduction to State and Local Taxation
This conference is designed for professionals new to SALT or seeking a refresher. Some of the topics include:

  • US Constitutional and federal constraints on state taxation
  • Overview of sales and use taxation
  • Overview of state corporate income taxation
  • State tax research tools, tips and tricks
  • State corporate income tax filing methods
  • Financial statement issues associated with state taxation

For a full list of topics, click here.

Intermediate State and Local Taxation
Tailored for experienced practitioners, this conference includes:

  • Ethics and state taxation
  • A roundtable tax discussion with senior government officials
  • Sales and use tax of software and digital products
  • Corporate income tax apportionment issues, including alternative apportionment
  • State taxation of foreign income
  • State taxation of partnerships and partners
  • Lobbying state and local tax issues

For a full list of topics, click here.

We hope to see you there! For more information or to register, click here.

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which state’s House of Representatives recently passed a bill that would allow small businesses to claim a personal income tax credit for providing employees with individual coverage health reimbursement?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

Members of our SALT team are on the move again this week with two exciting appearances:

2025 FTA Annual Meeting

On June 10, SALT Partner Jeff Friedman is pleased to present The Good, The Bad and The Strange 2025 during the 2025 FTA Annual Meeting in Chicago. He will help review some of the most notable, unusual and amusing legal cases in tax from the past year.

TEI Region 8 Annual Conference

On June 12, Partner Liz Cha and Counsel Chelsea Marmor will present State Tax Controversy – Update on Key Developments during TEI Region 8’s Annual Conference, held June 11-15 in Hilton Head, SC. Their session will cover some of the most important case developments from 2024 and 2025, addressing corporate income tax sourcing, apportionment, local taxes, and more. Liz and Chelsea will also provide insight regarding issues to watch and developing trends from jurisdictions across the country.

Don’t miss these opportunities to hear from our team!

We’re excited to introduce you to our June SALT Pets of the Month, Scout and Riley! These two lovable pups belong to Anna Schoenbaechler, Senior Tax Analyst at Cox.

Scout is a charming 6-year-old mixed breed with plenty of personality. Weighing 70 pounds, Scout was adopted as an 8-week-old pup from the Atlanta Humane Society in 2019. While his name is officially Scout, these days he answers to his nicknames “Scoot,” “Scooter,” or “Scooty.” Scout is a popcorn connoisseur, and when he’s not snacking, you’ll find him zooming around with his canine crew, living his best off-leash life. But don’t be fooled, Scout has a flair for the dramatic. If the other dogs won’t play, Scout isn’t shy about expressing his dismay. Despite his theatrical side, Scout is all heart. He’s friendly, good-natured, and always ready to wag his tail at both two-legged and four-legged friends.

Scout’s sister, Riley, is a 4-year-old potcake dog from the US Virgin Islands. Weighing in at 50 pounds, Riley was rescued as a stray and found her furever home through Furkids Atlanta in 2020. Riley is a true snack queen, with a soft spot for cheese and pumpkin. While she’s not exactly a fetch phenomenon, Riley more than makes up for it with an impressive prey drive. When she’s not on squirrel patrol, you’ll find her snuggled up for a cozy cuddle or riding shotgun on a car ride adventure.

Anna’s dynamic duo, Scout and Riley, bring plenty of personality and love to her home. Welcome to the SALT Pet of the Month family!