In this episode of the SALT Shaker Podcast, Partner Jeff Friedman sits down with Counsel Greg Matson to discuss his move to Eversheds Sutherland and reflect on a career spanning nearly every corner of state and local tax.

Greg shares insights from his time leading the Multistate Tax Commission (MTC), including the organization’s core programs and its push for greater uniformity in state tax laws. Their conversation also highlights a notable shift toward collaboration between states and the business community, as well as key projects like the MTC’s work on partnership audit rules.

The episode walks through Greg’s career path, from the IRS and DC Office of Tax and Revenue to taxpayer advocacy at TEI, before closing with some personal reflections, military service stories, and a lighthearted debate on airport moving walkways.

Don’t forget to check out Greg’s SALT Pet of the Month feature, starring his one‑eyed parrot, Slick.

For questions or comments, email SALTonline@eversheds-sutherland.com. Subscribe to receive regular updates hosted on the SALT Shaker blog.

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SALT Partner Jeff Friedman is looking forward to speaking during the 2026 Southeastern Association of Tax Administrators (SEATA) Annual Meeting, held this year in Greenville, SC. The annual meeting brings together leaders from SALT agencies to address the most pressing challenges facing tax administration in today’s evolving landscape.

Jeff’s panel will highlight significant and noteworthy SALT cases and developments, covering recent court decisions, legislative changes, and emerging trends affecting multistate taxation. The session will also explore practical implications for tax administration, including nexus, apportionment, and evolving compliance considerations.

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: According to a recent Massachusetts Department of Revenue newsletter, people temporarily in Massachusetts this summer competing in what event would be subject to state personal income tax?

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!

Federal tax changes continue to ripple through state revenue systems, and the implications are only becoming more complex.

This week, SALT Partner Charlie Kearns will speak at the Institute for State Policy Leaders’ State Tax Policy Seminar in Arlington, VA.

Charlie’s session will explore how states are responding to recent federal developments, including conformity decisions, shifting revenue considerations, and key issues to watch in the second half of 2026.

The seminar will cover a broad range of topics facing state policymakers, from economic nexus and digital goods to tax enforcement and data taxation, bringing together leading voices in the state tax policy arena.

To learn more about the program or to register, click here.

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.

Listen now:

Subscribe for more:

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.