Read our May 2018 posts on or read each article by clicking on the title. For the latest coverage and commentary on state and local tax developments delivered directly to your phone, download the latest version of the Eversheds Sutherland SALT Shaker app.


  • State Tax After TCJA: Treatment Of International Income
    The Tax Cuts and Jobs Act, P.L. 115-97,[1] made sweeping changes to the Internal Revenue Code, and will have far-reaching implications for state tax systems that broadly conform to the IRC. In this article for Law360, Eversheds Sutherland attorneys Jeffrey Friedman, Eric Tresh, Todd Lard and Todd Betor focus on the major state income tax implications of the TCJA’s international tax provisions, including: the transition tax imposed by revised IRC § 965; the foreign-source dividends received deduction, or DRD, allowed by new IRC § 245A; the tax on global intangible low-taxed income, or GILTI, in new IRC § 951A and related deduction in IRC § 250; the deduction allowed for foreign-derived intangible income, or FDII, in new IRC § 250; and the base erosion anti-abuse tax, or BEAT, imposed under new IRC § 59A.
  • A Pinch of SALT: Implications of the MTC’s Market-Based Sourcing Model Regulations
    It is more complicated to determine an in-state sale regarding the provision of multistate services or licenses of intangibles. Historically, states looked to a taxpayer’s costs of performing the service or licensing the intangible. Some states have become critical of this cost-of-performance method and replaced it with a market-based method of computing in-state sales. In this edition of A Pinch of SALT, Eversheds Sutherland Partner Jeffrey Friedman discusses the recent amendments to the Multistate Tax Commission’s (MTC) Model General Allocation and Apportionment Regulations; how the model regulations can be further improved; how states are responding to the model regulations; and what is next for the MTC.


  • Eversheds Sutherland SALT Shakes Things Up in the Big Easy!
    Eversheds Sutherland was delighted to sponsor and lead the two days of TEI’s Audit and Appeals seminar focused on State and Local Tax Controversy (May 2–3, 2018).
  • State and Local Tax Day
    The Eversheds Sutherland SALT team presented at the Tax Executives Institute (TEI) Denver Chapter State and Local Tax Day on May 15, 2018, in Lakewood, Colorado.
  • TEI’s 2018 Region II Forum
    Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary and ten breakout sessions offering a wide selection of federal, international, and state and local topics.