A Pinch of SALT

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In this installment of “A Pinch of SALT,” published by Tax Notes State, Partners Michele Borens and Jeremy Gove examine the evolving role of special industry apportionment rules and the Multistate Tax Commission’s efforts to modernize them.

The authors explore the history of these industry-specific sourcing and apportionment provisions, recent proposals affecting some of those…

In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Jeff Friedman, Charlie Kearns and Charles Capouet examine how declaratory judgment actions can provide an expedited resolution of challenges to state taxes. The authors analyze how courts and legislatures across the country allow – or prohibit – declaratory…

We’re pleased to share our recap of 2025’s state and local tax highlights, as featured in Tax Notes State.

This year’s Most Interesting State Tax (MIST) developments showcase the expanding scope of state income taxation, new constitutional tests, and the broadening reach of digital goods taxation.

Curious about what’s ahead for SALT in 2026?

Initially enacted as a temporary measure, Congress made ITFA permanent in 2016 to reflect the enduring federal commitment to preserve a tax-neutral digital infrastructure and protect an evolving digital economy. Indeed, today’s “internet access” is no longer defined by static homepages and email alone, but by cloud computing, digital advertising ecosystems, streaming platforms, and bundled…

California adopted UDITPA in 1966, with its equally weighted three-factor formula for apportioning multistate income – property, payroll, and sales. Over time, however, the sales factor has emerged as the primary mechanism for determining tax liability in California.

Today, California’s sales factor is the same as it was nearly 60 years ago. Although the fraction…

In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Charlie Kearns, Cyavash Ahmadi and Constance Chien examine different state approaches to exempting digital inputs, including uniformity efforts in the Streamlined Sales and Use Tax Agreement and under review by the Multistate Tax Commission. They also highlight states…

There is a lot of uncertainty around state tax penalties. The standards are murky because the authority to impose penalties often turns on whether a taxpayer exercised “ordinary business care” or had “reasonable cause” for its tax positions. And while many states use similar standards, courts interpret them differently.

Taxpayers are in a tough spot…

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…

For decades, the sales factor has been a primary focus of state and local tax articles and a hot topic of discussion at conferences across the country, and the attention is well deserved. There has been no shortage of impactful legislative changes, interesting administrative rulings, and significant (and at times frustrating) judicial decisions regarding the…

The California Franchise Tax Board’s method of taxing banks and financial institutions is consistently complex, and a bit messy. This complexity would worsen under the January budget proposal of California Governor Gavin Newsom to tax banks (and savings and loans) using single-sales-factor apportionment.

In this installment of “A Pinch of SALT” published by Tax Notes…