On September 22, 2026, the Supreme Court of Ohio unanimously held in Perrigo Sales Corp. v. Harris, Slip Opinion No. 2026-Ohio-3648, that the amount a prescription-drug manufacturer “realized” for purposes of Ohio’s Commercial Activity Tax (CAT) was the price it
Eversheds Sutherland LLP Blogs
Latest from Eversheds Sutherland LLP
These Rules Were Made for Walkin’: Texas Reboots Sales Tax on Data Processing and Information Services
Texas is changing course on two closely watched areas of sales taxation: data processing and information services.
In this episode of the SALT Shaker Podcast, Eversheds Sutherland’s Chelsea Marmor and Jeremy Gove break down the Texas Comptroller’s recent narrowing of
Regressive but not repressive: Ohio Supreme Court upholds financial-institutions tax against dormant Commerce Clause challenge
The Ohio Supreme Court unanimously affirmed a Board of Tax Appeals decision upholding the tax commissioner’s denial of a bank’s refund claims, holding that Ohio’s financial-institutions tax (FIT) is internally consistent and therefore does not discriminate against interstate commerce in
New York Appellate Division Determines Receipts from Buy/Sell Agreements Are Not Includible in Business Allocation Percentage
The New York Appellate Division, Third Department, affirmed a Tax Appeals Tribunal (TAT) ruling determining that Sunoco, Inc. (R&M) Combined Affiliates (Sunoco) was not permitted to include receipts from buy/sell agreements in its New York business allocation percentage (BAP) because
Lost in transit: California OTA holds cabinet fabrication labor performed in Mexico subject to use tax
A divided panel of the California Office of Tax Appeals (OTA) held that a California cabinet contractor owed use tax on fabrication labor bought from his Mexican affiliate. The panel found that the sale took place in Mexico, not California.
Matson’s Musings: Banking on Noncompliance
At COST’s annual meeting in San Antonio two weeks ago, I participated on a panel regarding state tax penalties. We focused on a troubling trend: states increasingly using penalties to raise revenue, whether by building them into newly enacted and
SALT trivia – October 14, 2026
Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!
We will award a prize for the smartest (and fastest) participant.
This week’s question: What is the name of the multistate agreement developed to
A bite of the pie: Indiana Supreme Court says wagering taxes stay deducted
The Indiana Supreme Court unanimously held that Penn Entertainment was not required to add back wagering taxes it paid to other states when computing its Indiana taxable income.
In the latest episode of the SALT Shaker Podcast, Partners Jeremy Gove
80/20 companies: Dispelling common misconceptions
Building on our prior Tax Notes State article that examined the history, purpose and policy rationale behind 80/20 company rules, Partners Jeff Friedman and Ted Friedman, and Associate Stephanie Terinoni, revisit the topic in this installment of “A Pinch of
New Jersey Tax Court upholds internet activity rules that narrow P.L. 86-272 protection
On October 1, 2026, the Tax Court of New Jersey ruled against the American Catalog Mailers Association (ACMA) in its challenge to the Division of Taxation’s 2025 regulations addressing when internet activity conducted by a foreign corporation within New Jersey