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
In GeTtin’ SALTy Episode 85, Nikki Dobay and Madeline Orlando discuss recent litigation involving state packaging extended producer responsibility laws and the potential implications for businesses subject to emerging EPR programs.
In GeTtin’ SALTy Episode 84, Nikki Dobay and Samantha Trencs discuss California Senate Bill 122, its expansion of sales tax to certain software and digital products, and related compliance considerations for businesses.
California’s CDTFA addressed stakeholder questions on proposed SB 122 regulations, including software and SaaS tax sourcing, MPU rules, contract transitions, and compliance ahead of the Jan. 1, 2027, effective date.
Continue Reading CDTFA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
In GeTtin’ SALTy Episode 83, Nikki Dobay and Glenn Newman examine New York City’s pied-à-terre tax, implementation hurdles, and potential legal challenges.
In a pending precedential decision, the California Office of Tax Appeals held that gain from the sale of a beverage distribution division was not apportionable to California because the division was not part of a unitary business.
Continue Reading California Office of Tax Appeals Rejects Unitary Business Treatment for Gain from Sale of Company Division
Nikki Dobay and guest DeAndré Morrow break down three landmark decisions issued by the Maryland Tax Court on Aug. 14 finding Maryland’s first-in-the-nation digital advertising tax unconstitutional on multiple grounds, including the Federal Internet Tax Freedom Act (ITFA), the Dormant Commerce Clause, the Due Process Clause, and the First Amendment.
Continue Reading GeTtin’ SALTy Episode 82 | Maryland’s Digital Advertising Tax Struck Down: The Tax Court Weighs In After Six Years of Litigation
In this episode of the GeTtin’ SALTy podcast, Nikki E. Dobay and Washington State Representative April Berg discuss a proposal to replace Washington’s longstanding B&O tax with a margins-based tax structure and explore broader state tax policy developments.
Continue Reading GeTtin’ SALTy Episode 81 | Washington’s B&O Tax: Time for a Change?
Colorado’s H.B. 26-1223 expands sales and use tax to software and SaaS beginning Jan. 1, 2027, but key sourcing and exemption questions remain unanswered as the Colorado Department of Revenue begins its rulemaking process.
Continue Reading Colorado Department of Revenue to Hold Work Group on Software Sales Tax Rules