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nyc_finance_logoNew York City’s Department of Finance (DOF) has issued the first tranche of proposed regulations under new Chapter 11A of Title 19 of the Rules of the City of New York (Proposed Rules) to implement its 2015 corporate tax reform—moving straight into formal rulemaking, in contrast with State’s multi-stage drafting process that culminated in December 2023. Although the City’s new Business Corporation Tax (BCT), applicable to corporations and banks that are not federal S corporations, largely mirrors the State’s framework, the Proposed Rules purposefully diverge in several places. The DOF has scheduled a virtual public hearing on the Proposed Rules for 11:00 am ET on November 20, 2025, and all written comments are due in advance of the hearing.

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Proponents have filed a California ballot initiative proposing a one-time wealth tax on individuals with more than $1 billion in net worth. The “2026 Billionaire Tax Act” would impose, for tax year 2026, a 5% tax on “all forms of personal property and wealth, whether tangible or intangible” exceeding $1.1 billion, with a slightly lower rate on amounts between $1-$1.1 billion. California residents, part-year residents, and certain trusts would be subject to the tax.  The initiative would also impose penalties ranging from 20-40% for understatements of the tax.

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After nearly a decade in development, the California Franchise Tax Board (FTB) has finalized its amended market-based sourcing regulation under Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.

The regulation was approved by the Office of Administrative Law and filed with the Secretary of State on August 27, 2025.  The revised rules will apply to tax years beginning on or after January 1, 2026.  Among the most significant changes to the regulation are:Capture-2-300x101

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Congratulations to our Pillsbury SALT team for earning recognition in the 2026 edition of Best Lawyers in America.

Partners Breann Robowski, Carley Roberts, Craig Becker, and Jeffrey Vesely were honored for their work in Litigation and Controversy – Tax and Tax Law. In addition, partner Evan Hamme was named to Best Lawyers: Ones to Watch.

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Best Lawyers: In America 2026

  • Breann Robowski
  • Carley Roberts
  • Craig A. Becker
  • Jeffrey M. Vesely

Best Lawyers: Ones to Watch

  • Evan M. Hamme

Congratulations to our outstanding colleagues on this well-deserved recognition!

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In a move to untangle the complexities surrounding sales and use tax in technology transfer arrangements, California’s tax regulator has laid out three major proposals.CDTFA-Logo-Horizontal-Full-2-300x91

SALT attorneys Jeff Vesely and Richard Nielsen dissect these changes—from adding clarification to introducing rebuttable presumptions—that could dial down uncertainty at the crossroads of sales/use tax and tech licensing agreements.

Read more on Pillsbury Law’s website.