Building on our prior Tax Notes State article that examined the history, purpose and policy rationale behind 80/20 company rules, Partners Jeff Friedman and Ted Friedman, and Associate Stephanie Terinoni, revisit the topic in this installment of “A Pinch of SALT,” taking a closer look at 80/20 companies and challenging several common misconceptions about their
In the News
NY Tax Talk: Evaluating the sales tax vendor relief program
New York’s new sales tax vendor re-registration program includes a potentially valuable penalty and interest discount program for eligible vendors. However, qualifying for the program may be more complicated than it first appears, particularly for taxpayers with unresolved controversies or liabilities that are not yet fixed and final.
In this installment of NY Tax Talk…
Special industry apportionment rules – refresh or fade away?
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…
Tax highlights from Georgia’s 2026 legislative session
In this Law360 article, Eversheds Sutherland attorneys Jonathan Feldman, Scott Wright, and Olivia Dibb provide analysis of key tax developments from Georgia’s 2026 legislative session, highlighting not only the enacted changes but their practical implications for taxpayers. They examine how accelerated income tax rate reductions, coupled with the repeal of certain credits, may affect tax…
Who doesn’t want to be a Washington millionaire?
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…
New York’s extension of the primary function test leaves taxpayers buzzing
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…
NY Tax Talk: Calculating tiered partnership income
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…
Utah porn and ad taxes would boost litigation more than revenue
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 two Utah proposals – a targeted advertising tax and a tax on online providers of material that is “harmful to minors” –…
Using a DJ to KO a bad tax: Expedited challenges to unconstitutional state taxes
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…
2025’s Most Interesting State Tax (MIST) developments
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?



