This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. 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 team hopes that you have found the SALT Scoreboard’s content useful. This edition includes discussions of the taxability of private line services and content delivery networks, as well as a spotlight on combined reporting decisions.
1st quarter 2025 In the first quarter of 2025, taxpayers prevailed in 31.0% (9 out of 29) of the significant cases.* In comparison, taxpayers have won 37.0% (51 out of 138) of the significant cases for 2024.
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