Meet Barclay, our July SALT Pet of the Month! This beloved 10-year-old Goldendoodle has been a devoted companion to Marilyn Wethekam, Of Counsel at the Council On State Taxation (COST), since he was just 8 weeks old.

His name is a clever nod to the US Supreme Court case Barclays Bank v. Franchise Tax Board, a fitting tribute in a SALT household!

Barclay is a true foodie, especially fond of anything his humans are enjoying. Cheese is a particular favorite! Mornings are reserved for long walks, his favorite daily activity. Besides that, he loves lounging on the couch or curling up in a welcoming lap and watching the Chicago Bears.

With his warm personality, Barclay is a welcome addition to our SALT Pet of the Month family!

Beginning in 2026, Georgia will have a new judicial branch tax court, replacing the existing Georgia Tax Tribunal, which currently operates within the executive branch.

In this installment of “A Pinch of SALT” published in Tax Notes State, Eversheds Sutherland attorneys Jonathan Feldman, Scott Wright, and Alla Raykin outline the benefits the new Georgia Tax Court offers taxpayers, as well as the laws that will govern the new court.

Most significantly, the new Georgia Tax Court is designed to preserve the benefits of the former tax tribunal while introducing a more streamlined appeals process. The new Georgia Tax Court process guarantees taxpayers a direct appeal to a Georgia appellate court, bypassing the Fulton County Superior Court and the subsequent discretionary appeal process.

Read the full article here.

SALT Partner Jeff Friedman is looking forward to speaking during the 2025 Southeastern Association of Tax Administrators (SEATA) Annual Meeting, held in Charleston, WV. His panel will cover significant, unusual and interesting SALT cases and developments.

Find out more and register 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: 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.