SALT partners Craig Becker and Robert P. Merten III will be presenting at this year’s CalTax Annual Meeting.
CalTax 100th Annual Meeting
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No Contract, No Look-Through: Wisconsin Draws a Line on Software Receipts Sourcing
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In a recent decision, the Wisconsin Tax Appeals Commission drew a bright line for sourcing receipts from software for sales factor apportionment purposes: without a contract with the end-user, a company cannot source receipts from software to the end-user’s location. 
Instead, the receipts must be sourced based on the location of the company’s immediate customer, even if most end-users are elsewhere.
Western States Petroleum Association 2026 PSAC Conference
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SALT partner Breann Robowski will be presenting at the Western States Petroleum Association 2026 PSAC Conference.
Press Mention: Aruna Chittiappa Analyzes New York Tax Case Poised to Shape SALT Law
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A recent Bloomberg Law article suggests the coming year could bring pivotal state and local tax rulings with implications that extend well beyond the individual disputes.
Pending cases in New York, South Carolina and Maryland raise key questions involving foundational state tax issues that SALT practitioners will be watching closely in 2026.
Press Mention: New York Tied to Narrowed Scope of Federal Corporate Transparency Act
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In a recent article published by TaxNotes, our colleague Andrew Weiner commented on New York Governor Kathy Hochul’s veto of legislation that would have decoupled the state’s LLC Transparency Act from the federal Corporate Transparency Act.
The veto keeps New York’s beneficial ownership disclosure regime aligned with the narrowed federal rules, raising state and local tax–related compliance and administrative questions for foreign-formed and multistate LLCs doing business in New York. The article discusses the resulting uncertainty, including the absence of state guidance and the potential for ongoing state-level filing obligations that do not exist under federal law.
To read more (article behind TaxNotes paywall): New York Tied to Narrowed Scope of Federal Corporate Transparency Act | Tax Notes
California’s Amended Wealth Tax Initiative Meets Five New Foes
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Proponents of the 2026 Billionaire Tax Act amended the initiative, prompting opponents to file five new initiatives aimed at undermining various aspects of the measure. The 2026 Billionaire Tax Act would impose a one-time wealth tax on California residents and trusts with “net worth,” defined in the initiative, exceeding $1 billion, as discussed more detail in our prior article.
California Alliance of Taxpayers Advocates Annual Conference
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SALT partner Breann Robowski will be speaking at the California Alliance of Taxpayer Advocates 2025 Annual Conference on December 12.
New York City Initiates Rulemaking Process for Business Corporation Tax
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New 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.
Billion-Dollar Question: California Initiative Targets the Ultra-Wealthy with One-Time Tax
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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.
2025 Annual Meeting of the Tax Bar and Tax Policy Conference
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Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III and Jeff Phang will be presenting at this year’s Annual Meeting on November 12–14, 2025.
