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SALT Implications of the One Big, Beautiful Bill Act

By , and 17 Mins Read

On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act (hereinafter, “OBBBA” or “the Act”) into law. OBBBA enacts sweeping changes to the Internal Revenue Code (“Code”), many of which will impact taxpayers at the state level, including reforms to the federal state and local tax (“SALT”) deduction, Global Intangible Low-Taxed Income (“GILTI”), Foreign-Derived Intangible Income (“FDII”), section 174 research and development expensing, and section 163(j) business interest deduction limitations. Notably,…

New Year, Same New York—Bill Proposes Significant Tax Increases for Corporations

By , and 5 Mins Read

Starting the new year off with legislation aimed directly at the pockets of corporate taxpayers, New York has issued a legislative proposal to nearly cut in half corporate taxpayers’ available GILTI exemptions, and at the same time almost double the top corporate franchise tax rate. Senate Bill 953 (“SB953”), pre-filed in the state senate on January 8, 2025, has the potential to significantly increase New York franchise tax exposure for corporations doing business in the…

Wayfair: The Sequel

By , and 6 Mins Read

A new lawsuit filed by Wayfair, LLC in Jefferson County Court (Colorado) seeks to address a question left open by the U.S. Supreme Court’s landmark 2018 Wayfair decision that permits states to impose a sales or use tax collection obligation based on an economic nexus threshold:  Does this decision apply to locally-administered sales or use taxes?  While many localities have asserted that the same economic nexus standards should apply at the state and local levels,…

Coronavirus Relief Bill Attempts to Address SALT Matters for Telecommuting Employees

By and 3 Mins Read

On Monday, July 27, the Senate Finance Committee released draft legislative provisions (“COVID-19 Bill”) regarding the next iteration of Coronavirus relief.  Somewhat surprisingly, the provisions include the Remote and Mobile Worker Relief Act of 2020, which was introduced earlier this year as S. 3995 by Sens. Sherrod Brown (D-OH) and Jon Thune (R-SD). S. 3995 appears to be based on S. 604, the Mobile Workforce State Income Tax Simplification Act (“Mobile Workforce Act”), which was…

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