Press Mention: Aruna Chittiappa Analyzes New York Tax Case Poised to Shape SALT Law

A recent Bloomberg Law article suggests the coming year could bring pivotal state and local tax rulings with implications that extend well beyond the individual disputes.

Pending cases in New York, South Carolina and Maryland raise key questions involving foundational state tax issues that SALT practitioners will be watching closely in 2026.

One such dispute now before a New York appellate court centers on claims by payroll and HR services provider Paychex Inc. that a New York State Department of Taxation and Finance regulation conflicts with the state’s corporate tax statute, which allocates income using New York receipts divided by total receipts.

According to Aruna Chittiappa, “the case sits at the intersection of statutory interpretation, appointment mechanics, constitutional limitations around retroactivity and agency deference.”

“What happens when the statute that’s been on the books since 2014 does not square with the regulations that the department has promulgated?” she asked. “That’s why this case is important on many different levels.”

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