Three State and Local Tax Cases Practitioners Must Watch in 2026

Next year has the potential for landmark state and local tax decisions that affect the broader legal landscape in addition to the discrete tax issues they address.

Pending cases in New York, South Carolina, and Maryland touch on apportionment, agency deference, digital taxation, and how courts should interpret state tax laws.

Here’s what SALT practitioners should watch for in 2026.

Paychex Inc. v. Dep’t of Taxation & Fin.

A dispute in a New York appellate court involving Paychex Inc. is raising some larger legal questions.

“The case sits at the intersection of statutory interpretation, apportionment mechanics, constitutional limitations around retroactivity, ...