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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…

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…

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…