On this episode of Greenberg Traurig’s GeTtin’ SALTy podcast, host Nikki Dobay and guest John Ormonde explore recent developments involving Public Law 86-272 and the limits it may place on state income-taxing authority.
They explain the difference between Joyce and Finnigan apportionment approaches, discuss why the Massachusetts Appellate Tax Board found that the state’s Finnigan
In a significant development for nonresident investors and private equity structures, the California Office of Tax Appeals (OTA) held that gain attributable to IRC section 751(a) “hot assets,” such as unrealized receivables and inventory items, remain part of the sale of a partnership interest. As the sale of an intangible interest, the sale of partnership
Recent state tax decisions address the scope of P.L. 86-272, evidentiary requirements for refund claims, and the classification of income from the disposition of business assets.
Continue Reading Recent State Income Tax Decisions and Their Potential SALT Implications for Multistate Businesses
Recent state court decisions are reshaping how states source receipts for income, franchise, and gross receipts tax purposes—particularly for businesses that sell through intermediaries.
Continue Reading Retail’s New Fault Line: ‘Ultimate Destination’ Reshapes Sales Sourcing
On June 18, 2026, the Massachusetts Supreme Judicial Court (SJC) held that a proposed initiative petition, No. 25-18, to reduce the Commonwealth’s personal income tax rate from 5% to 4% cannot appear on the November 2026 ballot. In Lewis Finfer & others v. Attorney General & others, SJC-13885, the Court found that the
Comments and testimony were submitted on proposed Illinois tax regulations addressing addback provisions for interest and intangible expenses.
Continue Reading Illinois Proposed Addback Regulations Raise Questions on Clarity, Administrability
A California budget trailer bill would extend sales tax to software and SaaS and adjust business credit limits, with potential implications for tax planning and compliance.
In this episode of the GeTtin’ SALTy podcast, host Nikki Dobay is joined by Greenberg Traurig colleagues Brad Marsh and Jennifer Vincent to discuss a significant recent victory in the California Court of Appeal – First Appellate District: Xavier Garcia-Rojas v. Franchise Tax Board.
The case involved a Texas-based radiologist who performed all of
In this episode of Greenberg Traurig’s GeTtin’ SALTy podcast, host Nikki Dobay is joined by Peter Blocker, vice president of policy at the California Taxpayers Association, and Alan Pasetsky, owner and founder of Tax Policy LLC, for an in-depth discussion of California Assembly Bill 1790 — a measure that, if passed, would repeal California’s Water’s
In this episode of GeTtin’ SALTy, podcast host Nikki Dobay welcomes back Representative April Berg of Washington’s 44th District for a deep dive into the 2026 landmark 60-day legislative session in Olympia.
Rep. Berg walks through the passage of Washington’s new tax — a 9.9% levy on individual income exceeding $1 million — marking the