Shaking things up in state and local tax
Shaking things up in state and local tax
When states push the limits of tax policy, litigation often follows.
In an article for Bloomberg Tax, Partner Jeff Friedman, along with University of Connecticut School of Law Professor Richard Pomp, examines Utah’s proposed advertising and “harmful to minors” taxes and explains why these measures may invite constitutional challenges rather than meaningful revenue.
Read…
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…
The third quarter of 2025 saw notable activity in New York tax law, including new appointments, regulatory changes, and key decisions.
In this installment of NY Tax Talk, a quarterly column in Law360 focused on recent developments in New York tax law, Eversheds Sutherland attorneys Liz Cha and Periklis Fokaidis highlight the filling of ALJ…
In this installment of Across State Lines in Tax Notes State, Eversheds Sutherland Senior Counsel Eric Coffill interviews Shane Hofeling, now chief counsel of the California Franchise Tax Board’s Technical Resources Bureau.
In their conversation, Shane shares insights on his vision for the Legal Division, the evolving role of artificial intelligence at the FTB, collaboration…
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 was a great deal of activity in New York in the second quarter of 2025, including several new cases and decisions concerning state and local taxes affecting taxpayers in New York State and New York City.
In this installment of NY Tax Talk, a quarterly column in Law360 focused on recent developments in New…
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…
