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Eric J. Coffill

As seen in: Bloomberg Law, Law360, JD Supra, Lexology, Financial Advisor, Bloomberg Tax, LexBlog, Open Legal Blog Archive
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Articles

Eversheds Sutherland SALT Scoreboard - Quarter 2, 2025

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By Todd Betor, Michele Borens, Elizabeth S. Cha, Jonathan Feldman Verified, Jeffrey Friedman, Ted Friedman, Timothy A. Gustafson, Charles C. Kearns, Daniel Schlueter, Maria Todorova, Eric Tresh, Scott Wright, Eric J. Coffill, Cyavash Ahmadi, Charles Capouet, Jeremy Gove, Chelsea Marmor, Laurin E. McDonald, John Ormonde, Alla Raykin, Madison Ball, Constance Chien, Periklis Fokaidis, Daniel Hopper, Sebastian G. Iagrossi, Dennis G. Jansen, Megan Long, Olivia Dibb, Leah Regan
| Lexology Verified
This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT team hopes that you have found the SALT Scoreboard’s content useful. This edition includes developments in investment tax credit limitations, the exhaustion of administrative remedies, and cloud service taxation.
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By Eric J. Coffill, Olivia Dibb
| Open Legal Blog Archive
The Virginia Court of Appeals recently held that the Virginia Department of Taxation cannot make it a requirement for a corporation to include the income and factors of a 17% owned LLC with its own income and factors as a unitary business. The taxpayer obtained the interest in question in exchange for the sale of several travel centers to a buyer LLC during bankruptcy proceedings.
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Don’t count on a sales tax discount: California Court of Appeal supports the validity of Regulation 1585

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By Eric J. Coffill
| LexBlog
The California Court of Appeal for the Third Appellate District held that the purchase of “discounted” cell phones bundled together with wireless services requires payment of sales tax based on the cell phone’s full price. Plaintiffs purchased cell phones at a reduced cost, together with wireless services, in a “bundled transaction.” The bundled transaction included the taxable sale of tangible personal property, as well as non-taxable sale of wireless services.
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