Hugh Wesley Goodwin

Recent Matters

• Represented major telecommunications service provider in US$24 million California income apportionment dispute
• Obtained a favorable result in a Texas unitary business hearing that overturned the original audit assessment
• Obtained a complete reversal of an audit assessment in a Washington sales tax and business and occupations tax dispute involving an out-of-state telecommunications business
• Assisted a manufacturer of electronic vehicles with US state income tax planning
• Revised existing operational structure to minimize sales and use tax collection obligations for company engaged in e-commerce marketplace transactions
• Developed legal analysis and strategy to support sales and use tax nexus position of nationwide consumer equipment seller engaged in online and in-store transactions
• Analyzed tax issues for successful appeal of a small business stock case before the California Supreme Court
• Assisted California equipment wholesaler with structure of distributor/reseller arrangements to minimize state sales tax collection obligations
• Counseled a major retailer in the formation of an intangible holding company and establishment of a gift card program to maximize unclaimed property benefits
• Obtained a favorable settlement in a US$2 million California tax dispute regarding the unitary nature of a taxpayer's commercial technology and government contracting businesses
• Developed a position for telecommunications equipment manufacturer in opposition to auditors' position regarding impact of stock option exercise by employee spouse on state income tax apportionment factors
• Advised a California software provider on the tax ramifications of establishing software development operations in other states
• Prepared a successful tax appeal in a case before the California State Board of Equalization for defense contractor concerning business/nonbusiness income characterization arising from the sale of stock
• Successfully represented a taxpayer in a dispute before the California State Board of Equalization regarding inadequate taxpayer notification of an assessment by the Franchise Tax Board
• Represented a husband and wife in a successful multi-million dollar California residency tax dispute

• Co-author, "The States' Evolving Approaches to Deference After Loper Bright," Tax Notes State, December 4, 2025
• Co-author, "SALT Implications of Federal Tariffs – Headache or Opportunity?" Tax Notes State, November 12, 2025
• Co-author, "Loper Bright and SALT Administrative Rulemaking," Tax Notes State, October 7, 2024
• Co-author, "The Fleeting Utility of Sports Wagering NOLs," Tax Notes State, February 5, 2024
• "'Quill' Pickle? How 'Wayfair' Could Undermine Some State Sales Tax Economic Nexus Provisions," Bloomberg BNA, June 27, 2018
• "Prudent planning helps minimize state tax liabilities," Franchising World, August 2012