In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more
This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
On January 21, 2025, New York Governor Hochul released her Fiscal Year 2026 Executive Budget and accompanying legislation (the Budget Bill). The Budget Bill includes a middle-class tax cut, a temporary personal income tax...more
This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
11/20/2024
/ Class Action ,
Commerce Clause ,
Corporate Taxes ,
Income Taxes ,
Like Kind Exchanges ,
Restricted Stocks ,
SALT ,
Severance Tax ,
State and Local Government ,
State Taxes ,
Tax Credits
California legislators released bill language addressing Governor Gavin Newsom’s “May Revise” to the state budget that includes the Governor’s so-called “apportionment fix.” If enacted, Assembly Bill 167 and Senate Bill 167...more
On May 10, California Governor Gavin Newsom introduced his “May Revise” of the state budget. In addition to net operating loss deduction suspensions and tax credit usage limitations, one particularly concerning corporate...more
This year’s Georgia’s legislative session is quickly progressing, with some major tax legislation moving towards passage. Last Thursday, February 29, 2024 was “Crossover Day”—the 28th legislative day of 40 total legislative...more
New York Governor Andrew Cuomo released his Fiscal Year 2021 budget and accompanying legislation on January 21, 2020 (the Budget Bill). Consistent with Governor Cuomo’s earlier promises, he has not proposed new taxes other...more
On December 26, 2019, in Matter of Mackenzie Hughes LLP v. New York State Tax Appeals Tribunal, the New York Supreme Court, Appellate Division, held that New York’s retroactive decertification of Qualified Empire Zone...more
1/7/2020
/ Business Taxes ,
Commercial Leases ,
Commercial Real Estate Contracts ,
Decertification ,
Due Process ,
Economic Development ,
Enterprise Zones ,
Limited Liability Partnerships ,
Multi-Factor Test ,
NY Supreme Court ,
Real Estate Development ,
Retroactivity ,
Reversal ,
Tax Appeals ,
Tax Authority ,
Tax Credits ,
Tax Tribunal
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more
12/26/2018
/ Apportionment ,
Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GDP ,
GILTI tax ,
Governor Murphy ,
Internal Revenue Code (IRC) ,
State and Local Government ,
State Tax Equalization Boards ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Revenues