The NYU School of Professional Studies returns this July with its annual Tax Conferences in New York City, bringing together government officials, leading practitioners, and in-house tax professionals.

We’re pleased to once again chair the Introduction to State and Local Taxation and Intermediate State and Local Taxation programs.

Introduction to State and Local Taxation
Designed for those newer to SALT, or professionals looking for a comprehensive refresher, this program offers a broad-based overview of state corporate income and sales taxation, including the constitutional limitations on state taxation. State corporate income tax topics include determining the tax base, formulary apportionment, return methods (including combined reporting), and financial statement issues. Sales tax topics include sales tax imposition statutes, common exemptions, marketplace issues, and gross receipts taxes. The course will also include a session on tax research tools and approaches. 

Intermediate State and Local Taxation
For practitioners with a working knowledge of SALT, the intermediate program focuses on complex issues and emerging developments affecting multistate taxpayers. The corporate income tax sessions include taxation of foreign income, alternative apportionment, and partnership taxation. The course also includes sessions on sales taxation of software and services, local taxation and a roundtable of discussion comprised of senior state tax government officials. 

Held in New York City, these programs offer a valuable opportunity to build practical skills, stay current on legislative and regulatory developments, and connect with leaders across the SALT community.

We hope to see you there.

In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor are joined by Counsel Charles Capouet to break down Illinois’ sweeping new tax legislation passed at the close of its legislative session, and signed by Governor Pritzker on Tuesday, June 16.

The group walks through several significant new taxes targeting the digital economy, including the newest state to impose a targeted advertising services tax, a new social media platform fee, and a first-of-its-kind digital asset privilege tax on cryptocurrency activity.

They break down how Illinois’ targeted advertising tax compares to similar regimes in Maryland and elsewhere, including key definitions, exemptions, and the importance of programmatic advertising concepts in determining taxability in Illinois. The conversation highlights the broader trend of states pushing into digital and emerging markets, and the resulting litigation and policy questions.

The episode also includes a rapid-fire overview of other notable provisions in the Illinois budget legislation, including expanded taxation of prediction markets and fantasy contests, as well as new limitations on corporate net operating loss carryovers.

The episode concludes with an overrated/underrated debate on s’mores, and the proper way to toast a marshmallow. For questions or comments, email SALTonline@eversheds-sutherland.com. Subscribe to receive regular updates hosted on the SALT Shaker blog.

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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: On June 5, Illinois Governor JB Pritzker announced a pause on processing tax incentive applications related to what type of economic development activity?

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

The prize for the first correct 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!

This month, we’re delighted to spotlight Murray and Alfie, a wonderful furry duo with very different personalities belonging to Stephanie Sargent, Tax Planning and Policy Manager at Starbucks.

Murray, an eight-year-old Aussiedoodle, joined the family as a puppy from San Diego. Alfie, a four-year-old Ragdoll and retired show cat, arrived a bit later but quickly claimed his role as king of the house.

Their names came together simply – both just felt right (with Murray pronounced like “Bill Murray” to avoid confusion with Murphy.) Stephanie also keeps a running list of future pet names, currently reserving Pier and Maurice for a hypothetical pair of donkeys.

Murray has developed a taste for the finer things – only name-brand dental treats, and a now non-negotiable Farmer’s Dog diet. Alfie’s preferences are less traditional. His favorite “treat” appears to be tape, and he reliably materializes whenever a package is opened.

Their routines reflect their personalities. Murray maintains an active social calendar with swimming and his dog walker group, while Alfie prefers window lounging, keeping watch and waiting for Murray to return home so he can remind him who’s in charge.

Both bring their own quirks. Murray takes television very seriously and barks at any on-screen animal (nature shows don’t stand a chance). Meanwhile Alfie, according to Stephanie, excels at silent judgment and well-timed inconvenience.

One standout moment in the pair’s journey: after an accident caused his dog walker’s car door to fly open, Murray ran nearly two miles home through San Francisco, where he was found calmly waiting at the front door. Alfie was waiting for him with open paws.

We’re so happy to feature this enthusiastic duo. Welcome to the SALT Pet of the Month family!

In a summary order issued May 20, 2026, the Supreme Court of Wisconsin declined to hear a petition for review filed by Skechers USA, Inc. (Skechers) concerning the Wisconsin Department of Revenue’s (Department) disallowance of corporate franchise tax deductions claimed for intercompany royalties. Justice Rebecca Bradley dissented but offered no written opinion explaining her reasoning.

The controversy began when Skechers formed a wholly owned subsidiary to hold its intellectual property (IP) and then paid royalty fees to the subsidiary to license the IP back. Skechers claimed deductions for its intercompany royalty payments in separate-entity states like Wisconsin. The Department disallowed the deductions on the basis that the intercompany transactions between Skechers and its subsidiary were sham transactions. Skechers appealed the Department’s disallowance, which ultimately was affirmed by the Wisconsin Tax Appeals Commission, the Wisconsin Circuit Court, and the Wisconsin Court of Appeals. Skechers’ appeal to the Wisconsin Supreme Court arose from a 2025 Wisconsin Court of Appeals decision that affirmed the Department’s application of the sham transaction doctrine to disregard Skechers’ intercompany royalty structure, holding that the relevant inquiry under Wisconsin law focuses on whether a transaction had a valid, non-tax business purpose or economic substance. The Wisconsin Court of Appeals rejected Skechers’ argument that application of the sham transaction doctrine should instead depend on whether its newly formed subsidiary was an independently viable entity engaged in substantive business activities, without evaluation of the transactions between Skechers and the subsidiary.  Rejecting Skechers’ reliance on non-Wisconsin reorganization cases, the court concluded that the taxpayer failed to demonstrate that the IP transfer and related licensing arrangements produced any practical economic effect beyond state tax savings.

While not an endorsement of the Wisconsin Court of Appeals decision, the Wisconsin Supreme Court’s denial of review leaves in place the Department’s position regarding application of the sham transaction doctrine.

Skechers USA, Inc. v. Wisconsin Department of Revenue, No. 2024AP957 (Wis. May 20, 2026).

The California Legislature may vote today on the Governor’s tax provisions, including sales tax on software. For additional background, see materials from our recent webinar on the proposal. The state Constitution requires the Legislature to pass a budget bill by June 15 at midnight. The Constitution also requires that a bill be in print for 72 hours prior to passage by the Legislature. On Friday, two budget trailer bills were introduced that incorporate the language of the Governor’s sales tax proposal and a credit limitation modification. 

SB 122:

  • Impose sales tax on electronically delivered or remotely accessed software beginning in 2027;
  • Extend the current business credit limitation and related refund provisions, which are currently set to expire after 2026, through 2029; and
  • Impose a credit cap of the greater of 70% of tax or $5 million beginning in 2030. 

SB 176:

  • Impose sales tax on electronically delivered or remotely accessed software beginning in 2027 (the same sales tax provisions as SB 122);
  • Adopt the Governor’s proposal to limit business tax credits to the greater of 50% of tax or $5 million in perpetuity beginning in 2027. 

While budget trailer bills are not subject to the June 15 budget deadline, each bill will have been in print long enough for the Legislature to vote on them today if it chooses to do so. Stay tuned.

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: On June 1, the U.S. Supreme Court declined to hear Florida’s challenge to California’s special apportionment rule for what type of income?

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

The prize for the first correct 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!

This week, members of our SALT team are taking the stage at two upcoming conferences, sharing insights on key state tax developments.

2026 FTA Annual Meeting

On June 9, SALT Partner Jeff Friedman is pleased to present during the 2026 FTA Annual Meeting in Nashville, TN. He will help cover the latest developments in SALT litigation.

TEI Region 8 Annual Conference

In addition, on June 11, Partner Liz Cha and Associate Madison Ball will present State Tax Controversy – Update on Key Developments and Trends during TEI Region 8’s Annual Conference, held June 10-14 in Hilton Head, SC. Their session will cover some of the most important case developments from 2025 and 2026, addressing corporate income tax sourcing, apportionment, local taxes, and more. Liz and Madison will also provide insight regarding issues to watch and developing trends from jurisdictions across the country.

Be sure to connect with our team at these events!

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 Midwestern state recently passed legislation that would impose a tax on the privilege of engaging in digital asset (e.g., cryptocurrency) business activity?

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

The prize for the first correct 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!

In this Law360 article, Eversheds Sutherland attorneys Jonathan Feldman, Scott Wright, and Olivia Dibb provide analysis of key tax developments from Georgia’s 2026 legislative session, highlighting not only the enacted changes but their practical implications for taxpayers. They examine how accelerated income tax rate reductions, coupled with the repeal of certain credits, may affect tax burdens and planning, and note that retroactive policy shifts could raise concerns about the long-term reliability of state incentives.

Read the full article here.