The datasheets do not do the design for you. They give you all the data
relevant to the part to do the thermal calculations, but you need to have external data to calculate/simulate the whole system, including the PCB.
For through-hole devices, this was easy as there were no custom parts in the thermal circuit: just add together Rth of junction-to-case, Rth of thermal interface material, and Rth of the heatsink.
But for SMD devices, PCB is always highly relevant; either it
is your heatsink, or even if you add an external heatsink, the PCB acts in series and often has significant thermal resistance. This tends to be the missing piece, because
you are the designer of the PCB, and hence no one else can produce that number for you.
Device datasheets tend to give you two extreme Rths, one wildly optimistic (device attached to an infinite heatsink with an extremely good thermal interface material), one wildly pessimistic (device mounted on a single-side FR4 PCB with minimal footprint, no internal layers, no thermal vias)... For your actual PCB, you'd either simulate it with some expensive thermal simulation software, or do your own simple guesstimates. I do simple back-of-the-envelope style thermal models in Excel.
Note that aluminum core PCBs are a real possibility. Coupled with a massive heatsink and highly thermally conductive and thin thermal pad as the interface medium, dissipation near 35W from a large DPAK/D2PAK size SMD device is certainly not impossible.
For standard FR4 without paying extra for copper-filled vias, it will be very difficult to get below around 10 K/W for the case-to-heatsink, as you need to go through thinly plated vias, and you can't extend the via array to infinity, as you'd face increasing thermal resistance on your top layer before getting to these vias.
This calculator:
http://circuitcalculator.com/wordpress/2006/03/12/pcb-via-calculator/ gives you the Rth of your vias.