Topic
Combined Reporting
55 published works
SALT Shaker
This week in SALT: TEI and COST speaking engagements
This week, members of our SALT team are on the speaking circuit, addressing foundational and emerging SALT issues at TEI programs and COST's 2026 Spring Meeting. Partner Jeff Friedman will…
SALT Shaker
New Hampshire Court holds unitary combined group member may offset gains using another member’s losses
The Merrimack County Superior Court held that the carryback long-term capital losses of one member of a unitary combined group can be used to offset the long-term capital gains of…
Cooking with SALT
South Carolina Legislature Reinforces Separate Reporting Regime, Slapping Department on the Wrist
Last week, South Carolina Governor McMaster signed into law Act No. 113 in a much needed reproach to the Department of Revenue’s aggressive attempts to undermine the state’s separate reporting…
SALT Shaker
Wading through the water’s-edge combined reporting method
By Jeremy Gove, Laurin E. McDonald
This episode of the SALT Shaker Podcast welcomes a new voice into the mix, Eversheds Sutherland Associate Laurin McDonald. Laurin joins host and Associate Jeremy Gove to describe 80/20 rules…
SALT Shaker
South Carolina Court upholds Department’s use of combined reporting under alternative apportionment statute
By John Ormonde, Eversheds Sutherland SALT
The South Carolina Administrative Law Court (ALC) held that the South Carolina Department of Revenue could require Tractor Supply and its affiliates to file a combined return notwithstanding that South…
SALT Shaker
The complex questions of combined reporting
By Jeremy Gove, Cyavash Ahmadi
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove teams up with Associate Cyavash Ahmadi to discuss the complexities of combined reporting, specifically comparing and contrasting the combined…
SALT Shaker
Colorado bills propose to adopt unitary combined reporting, add tax-haven provisions, and amend the definition of TPP to include digital goods
By Nikki Dobay, Ted Friedman, Jeremy Gove
Colorado House Bill No. HB21-1311 On May 10, 2021, Colorado House Bill No. HB21-1311 was introduced, which if enacted would make sweeping changes to Colorado’s unique combined reporting regime. Specifically,…
SALT Shaker
Much Ado About Nothing! Colorado Supreme Court Holds that Holding Companies with No Property or Employees are Not Includable in a Combined Group
By Chelsea Marmor, Open Weaver Banks
The Colorado Supreme Court issued two decisions simultaneously holding that neither Oracle Corporation nor Agilent Technologies, Inc. were required to include in their combined income tax returns holding companies that…
SALT Shaker
INSIGHT: Multistate Tax Commission considers alternative combined reporting statute, Public Law 86-272 guidance and post-Wayfair issues
In this article for Bloomberg Tax, Eversheds Sutherland attorneys Jeffrey Friedman, Stephanie Do and Michael Hilkin discuss the topics covered at the April 25 Multistate Tax Commission Uniformity Committee meeting in…
SALT Shaker
Taking Taxpayers for a Ride: California Upholds Mandatory Combined Reporting for Interstate Motorcycle Retailer
By Maria Todorova, Charles Capouet
The California Court of Appeals affirmed a trial court’s holding that the California Franchise Tax Board can require interstate unitary businesses to use combined reporting, even though combined reporting is…