Model SALT Administration: ABA Committee Pushes for Simpler, Fairer State Tax Systems

At the May 2025 ABA Section of Taxation meeting, the Model Administrative Subcommittee of the State and Local Tax (SALT) Committee offered a compelling update on its continuing work: creating a set of best practices to guide fair, transparent, and efficient state tax administration.

While tax policy debates often center on rates, credits, and exemptions, this subcommittee’s mission tackles the “how” of state tax enforcement—outlining principles that would help states build better administrative frameworks. Here’s a look at where the project stands and what’s coming next.

🎯 Guiding Goals of the Project

The Model Administrative Subcommittee’s report focused on developing a framework that encourages:

• Consistency across jurisdictions
• Transparency in the audit and appeal process
• Protection of taxpayer rights
• Efficiency in state tax enforcement
• Clear rules for multistate businesses

The goal is to provide model provisions that state legislatures, courts, and tax agencies can adopt—or at least benchmark against—as they revise outdated or opaque procedures.

📚 Working Draft in Progress

At the May meeting, the subcommittee reported that the first full working draft of the Model Administrative Code is underway. While the project is not intended to duplicate efforts like the Uniform Law Commission’s work, it borrows concepts from existing best practices and adapts them to the complexities of state-level SALT enforcement.

🔍 What Issues Are Being Addressed?

The report notes that the model provisions are expected to cover:

• Statutes of limitation and consistent filing deadlines
• Standardized appeal procedures
• Reasonable interest and penalty policies
• Uniform rules for audit selection, notice, and access to information
• Clarity in refund processes and overpayment procedures
• Respect for attorney-client privilege and tax practitioner roles

These areas reflect persistent friction points for businesses operating across multiple states, where compliance often involves navigating a labyrinth of procedural differences.

🤝 Collaboration Ahead

The subcommittee plans to collaborate with outside stakeholders, including state revenue officials, industry groups, and academic commentators. By integrating real-world feedback, the final recommendations can better serve both tax administrators and taxpayers.

The final product is envisioned as a “living model” — one that can evolve as technology, enforcement practices, and taxpayer needs change over time.

🧭 Why This Matters

For multistate taxpayers, complexity isn’t just annoying—it’s expensive. Procedural inconsistencies can lead to unintended noncompliance, duplicative audits, and costly litigation. A model framework for administrative fairness could reduce these inefficiencies and offer states a way to modernize their enforcement systems without sacrificing revenue.

While each state retains sovereignty over its own tax rules, the ABA SALT Committee’s work may offer the blueprint for what good SALT governance should look like in 2025 and beyond.

📅 What’s Next?

The Model Administrative Subcommittee plans to present a preliminary draft later in 2025, with a possible public comment period to follow. The committee welcomes input from practitioners who’ve seen firsthand how procedural gaps can derail compliance and trust in the system.

Stay tuned: If adopted or even partially emulated, these model administrative standards could reshape the taxpayer experience for years to come.