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In this installment of “A Pinch of SALT,” published by Tax Notes State, Partner Charlie Kearns examines Washington’s newly enacted “millionaire’s tax,” which takes effect in 2028 with returns due in 2029. The law imposes a 9.9% tax on Washington taxable income above $1 million, and introduces rules around residency, sourcing of income, and…

Bundled and mixed transactions continue to play an ever‑increasing role in New York sales tax determinations, particularly where nontaxable services are sold with software or other taxable property for one nonitemized price.

In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Jeremy Gove and Periklis Fokaidis examine…

Questions around federal conformity and the scope of administrative agency deference continue to shape New York City tax disputes.

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, Diane Beleckas, and Madison Ball analyze a recent determination of…

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…

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…