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For more than a decade, we have tallied the results of what we deem to be the significant taxpayer wins and losses and analyzed those results. This edition includes discussion of Public Law 86-272 and intercompany transfers, as well as a spotlight on Texas cases. _________ If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work. The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Services Tax US State and Local Tax Client Tools SALT Shaker Blog Key contacts Todd G. Betor Partner New York, United States Michele Borens Partner Washington, DC, United States Elizabeth S. Cha Partner New York, United States Jonathan A. Feldman Partner Atlanta, United States Jeffrey A. Friedman Partner Washington, DC, United States Ted W. Friedman Partner New York, United States Jeremy P. Gove Partner New York, United States Timothy A. Gustafson Partner Sacramento , United States Charles C. Kearns Partner Washington, DC, United States Chelsea E. Marmor Partner New York, United States Daniel H. Schlueter Partner Washington, DC, United States Maria M. 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All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website. For information on Konexo please also see the Legal Notices page of this website.

Eversheds Sutherland SALT Scoreboard – Quarter 1, 2026

May 11, 2026

United States

This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2026. For more than a decade, we have tallied the results of what we deem to be the significant taxpayer wins and losses and analyzed those results.

This edition includes discussion of Public Law 86-272 and intercompany transfers, as well as a spotlight on Texas cases.

_________

If you have any questions about this Legal Briefing, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Todd G. Betor

Partner

New York, United States

Michele Borens

Partner

Washington, DC, United States

Elizabeth S. Cha

Partner

New York, United States

jonathanfeldman@eversheds-sutherland.com

Jonathan A. Feldman

Partner

Atlanta, United States

Jeffrey A. Friedman

Partner

Washington, DC, United States

Friedman_Ted_portrait_web_newstyle new 2024

Ted W. Friedman

Partner

New York, United States

Jeremy P. Gove

Partner

New York, United States

Timothy A. Gustafson

Partner

Sacramento , United States

Charles C. Kearns

Partner

Washington, DC, United States

Chelsea E. Marmor

Partner

New York, United States

Daniel H. Schlueter

Partner

Washington, DC, United States

Maria M. Todorova

Partner

Atlanta, United States

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© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website. For information on Konexo please also see the Legal Notices page of this website.

Eversheds Sutherland SALT Scoreboard – Quarter 1, 2026

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