NEWS & INSIGHTS
COST in Action: SALT Policy Advocacy and State Tax Scorecards in 2025
The Council on State Taxation (COST) continues to play a central role in shaping state and local tax (SALT) policy across the country. As of May 2025, COST’s efforts span advocacy, litigation strategy, scorecard development, and deep engagement with uniformity projects.
📄 Legislative Comment Letters and Testimony
In the first half of 2025, COST submitted a high volume of comment letters and provided testimony on state tax bills affecting business taxpayers. Active jurisdictions include:
- Washington: Apportionment and tax administration reform
- Maryland: Legislative attempts to expand digital taxation
- California: Withholding guidance and income tax conformity
- Minnesota: GILTI treatment and proposed market-based sourcing shift
- Texas: Franchise tax simplification and sourcing rules
In addition, COST submitted targeted letters on sourcing, administrative provisions, and retroactive tax legislation in a half dozen other states, advocating for simplicity, clarity, and prospective-only changes.
⚖️ Improving Taxpayer Protections Through Uniformity
COST continues to push states toward more taxpayer-friendly and consistent SALT systems. Key uniformity proposals include:
- Extended statute of limitations following IRS adjustments
- Streamlined e-filing platforms and electronic correspondence options
- Prohibition on retroactive tax legislation
- Clearer unitary business standards
Much of this work is in coordination with the Multistate Tax Commission (MTC), where COST is providing technical input on model legislation and state implementation challenges.
📊 Scorecards: Rating the States on Tax Fairness
Scorecard season is back. In May 2025, COST released two high-impact reports:
- Sales Tax Systems Scorecard: Evaluates the fairness, transparency, and administrative burdens of state sales tax regimes. Florida and Texas scored high for electronic filing compliance; New York and Illinois ranked lower for complexity and audit frequency.
- State Tax Administration Scorecard: Measures states on timeliness, refund handling, audit procedure fairness, and appeals process clarity. Several states showed marked improvement over 2022, particularly North Carolina and Indiana.
A third scorecard on property tax administration is in development, with expected release later in 2025. Early indicators suggest growing concerns over local-level transparency and valuation challenges for industrial property owners.
💼 Looking Ahead: Business Input Driving Reform
Across state legislatures, agencies, and professional associations, COST is ensuring business taxpayer perspectives are represented in the ongoing evolution of SALT policy. From apportionment model bills to audit procedure reform, 2025 is shaping up to be a pivotal year.
With court challenges looming and digital economy rules evolving, COST’s work is becoming more essential than ever for companies navigating complex multistate operations.
Moffa Tax Law | Florida State and Local Tax Attorneys
The Council on State Taxation (COST) is a nonprofit organization advocating for fair and efficient state and local tax policy for multistate business taxpayers.
COST has filed comments or testimony in Washington, Maryland, California, Minnesota, Texas, and others on key SALT legislation.
A report that evaluates states on their sales tax administration, with rankings based on transparency, e-filing, and procedural fairness.
COST provides technical input on model laws and promotes uniform adoption of taxpayer-friendly standards developed in collaboration with the MTC.
Uniform audit procedures, electronic correspondence, prospective-only tax changes, and clarity in apportionment standards.
It evaluates the overall tax administration environment in each state, including refund practices, appeal processes, and audit treatment.
Retroactive laws can unfairly penalize businesses and create uncertainty in tax planning. COST advocates for forward-looking tax changes only.
A property tax scorecard is expected later this year, along with expanded advocacy on digital tax rules and business activity thresholds.
Businesses use scorecards to compare states for expansion, compliance planning, and lobbying purposes.
COST’s research, advocacy, and technical input help shape fairer SALT laws and provide critical updates for advisors and multistate taxpayers.
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Jeanette Moffa, Esq.
(954) 800-4138
JeanetteMoffa@MoffaTaxLaw.com
Jeanette Moffa is a Partner in the Fort Lauderdale office of Moffa, Sutton, & Donnini. She focuses her practice in Florida state and local tax. Jeanette provides SALT planning and consulting as part of her practice, addressing issues such as nexus and taxability, including exemptions, inclusions, and exclusions of transactions from the tax base. In addition, she handles tax controversy, working with state and local agencies in resolution of assessment and refund cases. She also litigates state and local tax and administrative law issues.
