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22 December 2025

State and local tax in 2026 - Apportionment, nexus, and the new digital reality

Is a website “cookie” the same as an actual one for purposes of being a physical presence for tax purposes? In this episode of DLA’s Tax Brief podcast, we welcome David Pope from our state and local tax group. We’ll unpack the cutting edge of state and local tax litigation to how states are rethinking apportionment and pushing the boundaries of § 86-272 in a digital economy. You’ll hear what’s really at stake as states wrestle with “look-through” approaches for software and services, test theories that cookies or chat functions create taxable presence, and much more!

Listen to The Tax Brief podcast on iTunes and Spotify.
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