Insights: Publications 4 Key Takeaways | A National State and Local Tax Update - Lexology

Kilpatrick’s David Hughes and Jordan Goodman gave a national SALT update at the high-profile AGN International “2025 Americas Regional Meeting” in Toronto on June 3.

Here are the four takeaways from their presentation:

1. Evolving Approaches to Income Tax Apportionment and Sourcing

Recent court decisions have clarified how states determine the apportionment and sourcing of income, particularly in multi-entity and cross-border scenarios. For example, in VA Dept. of Tax. v. FJ Management Inc ., the court emphasized the importance of functional integration and economies of scale when determining unitary businesses. Similarly, cases like Humana MarketPoint, Inc. v. MN Comm. Of Rev. and Amin v. NJ Div. of Tax. reinforce the need for clear statutory language and proper c