This month marks the beginning of operations for Georgia’s new Tax Court, which replaces the old Georgia Tax Tribunal. While the tribunal operated within the executive branch as part of the Office of State Administrative Hearings, the new Tax Court is part of Georgia’s judicial branch. It provides a pre-payment option for taxpayers to challenge
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Latest from SALT Shaker
SALT trivia – July 15, 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 recently approved a first-of-its-kind tax on electricity consumed by certain data centers?
E-mail your response to SALTonline@eversheds-sutherland.com.
The prize for the first…
All bets are off: Indiana’s add-back statute doesn’t cover intrastate wagering excise taxes paid to other states
By Greg Matson
In PENN Entertainment, Inc. v. Indiana Department of State Revenue, a unanimous Indiana Supreme Court reversed the tax court’s grant of summary judgment for the Indiana Department of Revenue requiring PENN Entertainment to add back approximately $2 billion in wagering excise taxes it paid to other states when calculating its Indiana adjusted gross income for…
Matson’s Musings: Thoughts from SEATA 2026 Conference
By Greg Matson
We’re pleased to launch the first edition of Matson’s Musings, a new weekly column from SALT Counsel Greg Matson. Each Thursday, Greg will offer his take on the latest SALT news, developments, and trends. Drawing on decades of experience, Greg will provide concise commentary and practical observations on the issues making headlines across the state…
SALT trivia – July 8, 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: New York City recently adopted its fiscal year 2027 budget which includes a new surcharge on what type of property?
E-mail your response to SALTonline@eversheds-sutherland.com…
South Carolina Court of Appeals upholds affiliated entities’ forced combination
The South Carolina Court of Appeals held that the South Carolina Department of Revenue properly required a retailer and its subsidiaries to file on a combined basis. In 2001, the retailer was restructured to create two affiliated subsidiaries. One of the subsidiaries engaged in inventory procurement for the other entities. Only the parent retailer entity…
California Court of Appeal holds Texas radiologist not a unitary business
The California Court of Appeal held that a Texas radiologist did not owe California personal income tax because it did not operate a unitary business in the state. During the years at issue, a medical corporation sent the Texas radiologist imaging studies collected at medical facilities in other states, including California. He then read the…
Cloud cover: Tennessee court shields software license receipts from business tax
In a recent decision, the Tennessee Court of Appeals addressed the business tax treatment of software licensing, cloud hosting, and cloud-based services, delivering a split decision with significant implications for taxpayers.
Background
SAP America, Inc. is a Delaware corporation engaged in selling or licensing enterprise resource planning software. SAP offers two primary models for customers…
SALT trivia – July 1, 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: The U.S. Supreme Court recently considered a tax foreclosure case involving a family from which state?
E-mail your response to SALTonline@eversheds-sutherland.com.
The prize for the…
Welcoming Greg Matson: A pretty slick SALT career
In this episode of the SALT Shaker Podcast, Partner Jeff Friedman sits down with Counsel Greg Matson to discuss his move to Eversheds Sutherland and reflect on a career spanning nearly every corner of state and local tax.
Greg shares insights from his time leading the Multistate Tax Commission (MTC), including the organization’s core programs…