In Matter of Petosa, the New York Tax Tribunal forced a state tax S corporation election on a corporation doing business in New York because its gain from the sale of corporate goodwill caused gain and income from investment property to exceed 50% of the total income earned by the corporation in the year of the sale. Not only did this holding result in additional New York tax to be payable, the shareholder level tax was not deductible for federal income tax purposes (whereas the corporate level tax would have been deductible). In “SALT in the Wound: New York Imposes Shareholder-Level Tax on Corporate Asset Sale,” colleagues Mark Leeds and Jack Camillo analyze the case and explain why it provides a cautionary tale for corporate asset sales of companies doing business in New York.
2026 COST Spring Conference
SALT partners Aruna Chittiappa and Evan Hamme will be speaking at COST’s Spring Conference taking place April 20-23, 2026 in Coral Gables, FL.
California Groups File Signatures for Initiative to Curtail Local Taxes
A coalition of business and antitax groups announced that it has submitted more than 1.3 million signatures to qualify the “Local Taxpayer Protection Act to Save Proposition 13” for the November 2026 ballot. These groups include the Howard Jarvis Taxpayers Association, the California Business Roundtable, the California Taxpayers Association, and the California Business Properties Association.
TEI’s 2026 Midyear Conference
Pillsbury SALT attorney Jack Camillo will be speaking at TEI’s 2026 Midyear Conference on March 18.
Not the CAT’s Meow: Ohio Supreme Court Reins in the Continuous Delivery Theory for Situsing Receipts
Recent Ohio Supreme Court decisions addressing the situsing of receipts under the Commercial Activity Tax (CAT) underscore both the limits of the “continuous delivery theory” and the evidentiary hurdles taxpayers face when seeking refunds for transactions involving Ohio distribution centers.
Read together, VVF Intervest, L.L.C. v. Harris, Slip Op. No. 2025-Ohio-5680 (Ohio Dec. 24, 2025), and Jones Apparel Group/Nine West Holdings v. Harris, Slip Op. No. 2026-Ohio-74 (Ohio Jan. 14, 2026), confirm a transaction-focused approach to CAT situsing while highlighting the evidentiary showing required to substantiate refund claims.
2026 ABA-IPT Advanced State Income Tax Seminar
Pillsbury SALT partner Carley Roberts will be presenting at the 2026 ABA-IPT Advanced State Income Tax Seminar on March 17.
Welcome to Pillsbury SALT, Lauren!
Pillsbury SALT is excited to welcome Lauren Durborow to the team!
Lauren’s experience includes variety of state and local tax matters, including multistate litigation, planning, audit defense and controversy issues.
She joins Pillsbury’s New York office as an associate.
5 Questions with Lauren: Continue Reading ›
Sacramento Young Tax Lawyers Webinar
SALT attorney Jeff Phang will be presenting at an event hosted by the Sacramento Young Tax Lawyers (SacYTL), in collaboration with the California Lawyers Association – Tax Section.
COST’s SALT in a Digital World Workshop
SALT partners Carley Roberts, Robert P. Merten III, Aruna Chittiappa and Evan Hamme will be speaking at COST’s Digital Workshop taking place March 2–4, 2026.
CalTax 100th Annual Meeting
SALT partners Craig Becker and Robert P. Merten III will be presenting at this year’s CalTax Annual Meeting.
