On July 22, 2026, the Massachusetts Appellate Tax Board held that the Massachusetts Commissioner of Revenue could not use a Finnigan-style sales reallocation rule to include Massachusetts receipts of a P.L. 86-272 protected affiliate in the sales factor numerators of
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This week in SALT: NESTOA, TEI and California tax updates
Join Eversheds Sutherland SALT attorneys at upcoming conferences and webinars addressing recent developments in SALT litigation, California tax and tax leadership.
2026 Northeastern States Tax Officials Association (NESTOA) Annual Meeting
On August 24, SALT Partner Jeff Friedman will present “The
Matson’s Musings: Purloined interest
Almost all law schools require criminal law, typically in the first year. Among the memorable lessons of that course is that theft is not a single idea. It is a family of offenses involving the wrongful taking or keeping property
Register now | TEI’s Audits & Appeals Seminar SALT Track (Sept. 8-9, 2026)
Eversheds Sutherland is proud to sponsor the State and Local Tax Controversy program at the Tax Executives Institute’s 2026 Audits and Appeals Seminar, held at the Capital One Conference Center in Tysons, VA.
State and Local Tax sessions include:
- Anticipating State
SALT trivia – August 19, 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: Which state’s supreme court recently ruled that a fee imposed
Paychex v. New York: Procedure before substance
In this episode of the SALT Shaker Podcast, hosts and Partners Jeremy Gove and Chelsea Marmor discuss the New York Appellate Division’s recent decision in Paychex v. Department of Taxation and Finance. Although the underlying dispute concerns whether certain
California OTA confirms severance payments are sourced to a nonresident’s domicile
The California Office of Tax Appeals (OTA) held that severance payments and employer-paid medical premiums received following an employee’s termination constituted income from intangible personal property and were therefore sourced to the taxpayer’s Nevada domicile. The taxpayer, a former California-based
SALT Pet(s) of the Month: Rackham and Abbie
This month’s featured pets are Rackham and Abbie, the seafaring companions of Perry Cooper, Senior Legal Reporter at Bloomberg Law.
Rackham, a 9-year-old Mini Australian Shepherd, is named after the 18th-century pirate Calico Jack Rackham, who was reportedly better known
Matson’s Musings: Are all MTC members the same?
At its inception, membership in the Multistate Tax Commission (MTC) was straightforward. It consisted of each state that was a party to the Multistate Tax Compact – that is, each state that had statutorily enacted it. Those members, including the
Special industry apportionment rules – refresh or fade away?
In this installment of “A Pinch of SALT,” published by Tax Notes State, Partners Michele Borens and Jeremy Gove examine the evolving role of special industry apportionment rules and the Multistate Tax Commission’s efforts to modernize them.
The authors explore the history