On October 28, 2025, Florida filed a motion for leave to file a bill of complaint in the United States Supreme Court challenging California’s business income tax apportionment regulation, alleging it unconstitutionally discriminates against out-of-state corporations. The case invokes the Court’s original jurisdiction over disputes between states, a mechanism reserved for matters of sufficient seriousness
Alysse McLoughlin and Katie Quinn authored a recent installment of SALTy Thoughts in Tax Notes on July 31, 2025.
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After a suspenseful few months, on July Fourth President Trump signed the One Big Beautiful Bill Act (OBBBA, P.L. 119-21) into law. Among the bill’s many changes are amendments to the global intangible low-taxed
Jones Walker SALT Partner Katie Quinn will present “Corporate Income Tax Apportionment Issues, Including Alternative Apportionment” on July 23, 2025 in New York. The Intermediate State and Local Taxation Conference presents in-depth analysis of complex problems state and local tax professionals regularly encounter and provides attendees with practical skills and strategies to manage these issues.
Chris Lutz, a partner on the state and local tax team in the Washington, DC office, was quoted in the Tax Notes State article “SCOTUS Urged to Address External Consistency Gray Area in Use Taxes” published on November 4, 2024.
The article outlines Chris’ back-and-forth with Massachusetts’s General Counsel regarding whether the Constitution requires
Alysse McLoughlin and Katie Quinn, partners on the state and local tax team in the New York office, authored the article “Moore Gives Taxpayers a ‘Gotcha’ Argument In Factor Representation Cases” published in the SALTy Thoughts section by Tax Notes State on September 9, 2024. In the article, Alysse and Katie discuss the Supreme
Jones Walker SALT Team partner Katie Quinn will present “Making Sense of the Complex Wave of Financial Transaction Taxation” at the Institute for Professionals in Taxation 2024 Annual Meeting on June 24 in San Diego, CA.
Jones Walker SALT Team partner, Alysse McLoughlin, will present on the “SALT in the Wound” panel at the COST Spring Conference. States continue to test the constitutional limitations on their taxing authority, and are sometimes successful in doing so. The panel will discuss the pivotal cases and the application of those decisions by
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 regime for apportioning corporate income. While the law creates a new paradigm for how and in what manner the state or taxpayer may obtain alternative
Mississippi Taxpayers should keep a very close eye on the Toolpushers Supply sales tax case just granted certiorari by the Mississippi Supreme Court. This case addresses important sales tax issues related to wholesale sales and the extent to which a seller must audit its purchaser’s downstream use of the goods on purported resale transactions. More
In Matter of Sunoco Inc. (R&M) Combined Affiliates, a Division of Tax Appeals Administrative Law Judge (ALJ) determined that Sunoco’s sale of oil pursuant to buy/sell arrangements was not a “sale” for purposes of computing Sunoco’s New York State Article 9-A sales factor. The ALJ’s determination was based upon her finding that Sunoco was