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In this article, originally published by CalCPA in the January/February 2025 issue of California CPA, Eversheds Sutherland Senior Counsel Eric Coffill spotlights the recent disappearance of Technical Advice Memorandums (TAMs) from the California Franchise Tax Board (FTB) website.

Read the full article here.

Apportionment formulas sometimes produce unfair results. To rectify the unfairness, taxpayers can (and should) use an alternative apportionment formula to apportion corporate income. In their article for TEI’s Tax Executive journal, Eversheds Sutherland attorneys Jeff Friedman and Sebastian Iagrossi focus on a troubling aspect of alternative apportionment— some states require pre-approval of an alternative apportionment…

Courts have formulated more than a dozen legal canons of statutory construction specific to tax.

In the October 2024 installment of “A Pinch of SALT” in Tax Notes State, Eversheds Sutherland attorneys Jeff Friedman, John Ormonde and Kelly Donigan examine the application of statutory construction principles to conflicts involving allocation and apportionment statutes.

Because…

In the aftermath of the US Supreme Court’s 1984 decision in Chevron U.S.A. Inc. v. Natural Resources Defense Council Inc., federal judges became exceedingly deferential to administrative agencies’ interpretations of apparently ambiguously drafted laws. As the impact of Chevron evolved, flaws in its holding became apparent across almost every area of law, including tax.…

In an article published by Savannah Morning News, Eversheds Sutherland SALT Partner Jonathan Feldman discusses a proposed constitutional amendment on the Georgia ballot this November that would create a new judicial branch tax court with the same judicial power as superior courts. Appeals from the new tax court would go directly to the Georgia…

In response to concerns that the District of Columbia needed to explore new or broadened revenue sources, the D.C. Council established D.C.’s Tax Revision Commission to comprehensively review the District’s tax code. The Commission’s mandate is to make tax policy recommendations, and it began meeting in 2022 with the intent of making tax recommendations to…

In one fell swoop, Loper Bright rebalanced the way in which federal courts will apply federal regulations and other administrative guidelines.

In his Board Brief for Tax Notes State, Eversheds Sutherland SALT Partner Jeff Friedman explains how the U.S. Supreme Court’s decision to reverse Chevron will have short-term and long-term consequences regarding the application…

In December 2023, the Financial Accounting Standards Board added significant income tax disclosure requirements to the already cumbersome and complex checklist of state tax financial statement disclosure rules.

In this installment of A Pinch of SALT published in Tax Notes State, Eversheds Sutherland attorneys Todd Betor and Jeff Friedman discuss the Financial Accounting Standards…