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The SALT Shaker PodcastAuthor: Eversheds Sutherland
State and local tax jurisdictions continue to evolve their tax systems around the US. Analyzing the latest key decisions, legislative and regulatory changes, and revenue agency guidance, the Eversheds Sutherland SALT Team focuses on providing tax professionals with a quick update of the most important developments in US state and local tax. The SALT Shaker Podcast helps tax professionals navigate growing challenges in the evolving tax systems of state and local jurisdictions. Language: en Genres: Business, Business News, Management, News Contact email: Get it Feed URL: Get it iTunes ID: Get it |
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Alabama Court addresses interest expense add-back and the subject-to-tax exception
Thursday, 12 November, 2026
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor unpack a recent Alabama Court of Civil Appeals decision involving the state's interest expense add-back statute and the "subject-to-tax" exception. They walk through the intercompany financing structure at issue and the court's conclusion that an intermediary affiliate effectively served as a conduit for payments ultimately received by related entities in another jurisdiction. Jeremy and Chelsea discuss why the flow of funds, the substance of the entities involved and the standard of review proved critical to the outcome, as well as what the decision may mean for taxpayers evaluating multi-step intercompany financing arrangements. They also touch on the court's treatment of confidentiality and sealing issues, including the importance of clearly documenting agreements concerning confidential taxpayer information. And, of course, no episode is complete without Overrated/Underrated. This week's question: Is Black Friday overrated or underrated now that holiday sales seem to last all month? For questions or comments, email SALTonline@eversheds-sutherland.com. You can also subscribe to receive our regular updates hosted on the SALT Shaker blog.
