5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
This was a question often raised during the annual Council On State Taxation (COST)/Tax Leadership Roundtable Southeast Regional SALT Update held earlier this month at the Encompass Health headquarters in Birmingham. The...more
Kilpatrick’s Jordan Goodman recently co-presented the session “Income Subject to Allocation” at the Institute for Professionals in Taxation’s “2025 State Income Tax School” in Atlanta. Jordan addressed the distinction between...more
One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and the Investment Tax Credit...more
Kilpatrick’s David Hughes and Jordan Goodman gave a national SALT update at the high-profile AGN International “2025 Americas Regional Meeting” in Toronto on June 3....more
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...more
The South Carolina Court of Appeals determined that Duke Energy Corporation (“Duke”) was entitled to claim nearly $25 million in investment tax credits on its 1996 to 2014 South Carolina income tax returns, as the investment...more
Consistent with the decisions in several other states interpreting the Uniform Division of Income for Tax Purposes Act’s (“UDIPTA”) definition of nonbusiness income, an Arkansas Circuit Court concluded that gains from the...more
Founders and executives with equity compensation need to be prepared for state tax exposure, even in states where they do not live. In a landmark decision that reverberates beyond Massachusetts, the Massachusetts Appeals...more
Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more
The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more
The Department of Revenue (the “Department”) recently released two documents containing its “substantive” and “clarifying” requests for legislative changes to North Carolina’s revenue laws. Most of the requests include...more
The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more
Gross receipts from healthcare services delivered to dialysis patients were properly sourced to Ohio where the treatments were performed. Accordingly, the patients received the benefit of the dialysis services at the...more
I recently posted a blog about Texas sales tax nexus in which I laid out the basic rules for determining whether a taxpayer has nexus with the State of Texas (and thus has a permit, collection, and/or reporting requirement...more
This is a reminder that annual report filings are due in March 2025 for corporations formed or registered in Delaware and Massachusetts. New York biennial statements are due the last day of the calendar month in which a...more
A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more
The Supreme Court of Ohio upheld the denial of Total Renal Care, Inc.’s (“TRC”) refund claim of Ohio Commercial Activity Tax (“CAT”) that it paid on services that it performed outside of Ohio. Total Renal Care Inc. v. Harris,...more
Last week, on Jan. 15, Gov. Wes Moore introduced to the Maryland General Assembly his fiscal year 2026 budget package. This $67.3 billion proposal, aiming to close the state’s nearly $3 billion budget gap, places a strong...more
When examining the tax structures of business-aggressive states, a common pattern emerges: reduced income and franchise taxes offset by steeper sales and property taxes. While this approach may work for some industries, it...more
From understanding how businesses are taxed to navigating changes in Ohio tax regulations, it’s important to be aware of potential tax hurdles and how to proactively avoid them. This article from Buckingham, Doolittle &...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
This Alert summarizes all the material amendments to Chapter 105 of the North Carolina General Statutes ratified to date during the General Assembly’s 2024 short session....more
This is the first 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
Preparing for significant changes to Ohio commercial activity tax for 2024 – Majority of taxpayers will no longer be subject to CAT following increases in annual exclusions. Ohio’s Budget Bill (H.B. 33) significantly...more
As the New Jersey Division of Taxation changes leadership and issues guidance regarding legislative changes, including for unity, it is time to recall some fundamentals of unity and put the unity statute change in context....more