Tax Law

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Eversheds Sutherland SALT Scoreboard Publication–Third Quarter 2018
Posted on 1 Nov 2018 by Eversheds Sutherland LLP

This is the eleventh edition of the Eversheds Sutherland SALT Scoreboard, and the third edition of 2018. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses and analyze those results. This edition of the SALT... Read More

Minnesota Tax Court Clarifies R&D Credit Calculation in Identical Cases
Posted on 18 Oct 2018 by Eversheds Sutherland LLP

In two cases, the Minnesota Tax Court clarified the extent to which the Minnesota research and development (R&D) credit is calculated based on the Internal Revenue Code’s defined terms. Minnesota law incorporates the Internal Revenue Code’s definition... Read More

North Carolina Supreme Court Decides in Favor of Taxpayer in Trust Nexus Dispute
Posted on 11 Jul 2018 by Eversheds Sutherland LLP

The North Carolina Supreme Court recently held that the presence in the state of a trust’s beneficiary is not sufficient to establish income tax nexus for the trust. In the Kimberly Rice Kaestner 1992 Family Trust case, the trust’s beneficiaries were... Read More

New Mexico Finds No Obstacle to Inclusion of Foreign Dividends and Subpart F Income in Consolidated Return Base
Posted on 26 Apr 2018 by Eversheds Sutherland LLP

The New Mexico Administrative Hearings Office affirmed the Taxation and Revenue Department’s assessment based on General Electric’s exclusion of foreign dividend and Subpart F income from its base income in its New Mexico consolidated return. In this... Read More

Oregon Deems Amendments to Statutory State Apportionment Formulas to Be Constitutional
Posted on 4 May 2018 by Eversheds Sutherland LLP

In another of the so-called “Compact” cases, the Oregon Supreme Court affirmed the decision of the Oregon Tax Court and held that: (1) the 1967 Oregon Legislature, in enacting Oregon Statute Section 305.655, did not clearly and unmistakably intend for... Read More