SALT attorneys Zachary Atkins, Evan Hamme and Aruna Chittiappa will each be speaking at COST’s State Indirect Tax Seminar on December 13, 2023 in Atlanta, GA.
60th Annual TEI New York Chapter Tax Symposium
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Zachary Atkins will be speaking at the 60th Annual TEI New York Chapter Tax Symposium on December 6.
No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01
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In the Appeal of Southern Minnesota Beet Sugar Cooperative (2023-OTA-342P) (Beet Sugar), the California Office of Tax Appeals (OTA) issued a precedential opinion holding the California Franchise Tax Board (FTB) is not entitled to apply its FTB Legal Ruling 2006-01 (Apr. 28, 2006) to prohibit taxpayers from including in their apportionment factors property, payroll, and sales that generated statutorily deductible income. The OTA’s guidance on the FTB’s interpretation and application of Legal Ruling 2006-01 in this opinion also has implications beyond the specific issue in Beet Sugar, as the FTB has been attempting to expand the application of the limited legal ruling to other inapplicable situations. For example, an opinion by the OTA in the Appeal of Microsoft Corporation & Subsidiaries (OTA Case Number 21037336) is also anticipated to be issued soon, which appeal concerns whether the FTB is entitled to apply Legal Ruling 2006-01 to prohibit taxpayers from including in their apportionment sales factors statutorily deductible foreign dividend amounts.
Congratulations Carley Roberts! Recipient of the 2023 Benjamin F. Miller Award
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The entire Pillsbury State and Local Tax (SALT) Team is very proud to congratulate our practice leader Carley Roberts for receiving the prestigious Benjamin F. Miller award during this year’s California Annual Meeting of the Tax Bar and Tax Policy Conference.
This award is presented annually by the California Lawyers Association’s Taxation Section to recipients recognized for having achieved professional excellence and notable contributions in the field of state and local taxation law akin to the attorney the award is named after, Benjamin F. Miller.
Carley has been achieving professional excellence and notable contributions to SALT, both in California and nationwide, for approximately 25 years and counting. Throughout this quarter century, Carley has also worked prolifically towards successfully garnering effective collaboration and cooperation between the private and public sectors of SALT.
Congratulations Carley!
Read more: Carley Roberts Honored with Benjamin F. Miller Award by California Lawyers Association
Pillsbury SALT Attorneys Zack Atkins and Evan Hamme Serve as Panelists at Paul J. Hartman State & Local Tax Forum
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State & Local Tax special counsel Zack Atkins and counsel Evan Hamme recently served on panels discussing important developments in state and local tax at the Paul J. Hartman State and Local Tax Forum in Nashville, Tennessee.
Read more about their panels on Tax Notes (subscription required): Panelists Discuss Challenges of True Object Test for Mixed Transactions | Tax Notes and Transfer Pricing Relevant for Addback Exceptions, Panel Says | Tax Notes.
Pillsbury SALT Team at COST’s 54th Annual Meeting
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The Pillsbury SALT team had a memorable time last week at COST’s 54th Annual Meeting in Las Vegas, NV. Carley Roberts, Zachary Atkins and Evan Hamme were all speakers during the annual meeting, and the rest of the team attended a variety of substantive sessions on SALT issues and state tax trends. On Wednesday evening, the team also hosted a unique and memorable client event in the SKYLOFTS at MGM Grand.
2023 Annual Meeting of the Tax Bar and Tax Policy Conference
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Join Jeff Phang, Jeff Vesely and Robert Merten on day two of the California Lawyers Association’s 2023 Annual Meeting of the Tax Bar and Tax Policy Conference, when they will each speak on separate panels.
9:40 – 10:40 AM Sourcing Income from Passthrough Entities & Developments Since Metropoulos – Jeff Phang
This panel will focus on the interplay between the California personal income tax law and the tax law for entities in the context of sourcing income—namely, income derived from an ownership interest in a pass-through entity or the sale of that ownership interest.
10:50 – 11:50 AM California Litigation Update – Robert Merten
This panel brings together well-known speakers from the Franchise Tax Board, California Department of Tax and Fee Administration and private practice for a candid overview of the important developments of SALT litigation on a national and state level.
1:45 – 3:15 PM Substantial and Occasional Developments in Alternative Apportionment for Corporate Income Tax – Jeff Vesely
This panel will discuss California’s alternative apportionment rules with a focus on the Substantial and Occasional Sale rule.
For more information or to register, please visit the event page.
Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business
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On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT)[1] including expanding the definition of what constitutes a “unitary business.” The expanded definition now includes affiliated entities that may not have previously met the requirements for combined group membership for CBT purposes. 
California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid
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A California trial court denied summary judgment in the American Catalog Mailers Association’s (ACMA) action that seeks to invalidate Franchise Tax Board (FTB) guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes. However, the court signaled it may invalidate the FTB’s guidance on the basis it constitutes underground regulations and violates California’s Administrative Procedure Act. Continue Reading ›
TEI’s 2023 Annual Conference
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Please join Pillsbury partner Jeff Vesely at TEI’s 2023 Annual Conference – a 75th Anniversary Celebration in New York City. Jeff will be participating on a panel titled, “State Tax Policy: As Deficits Return Will the Tide Change?” This conference will take place October 22 – 25 at the New York Marriott Marquis Hotel.
In celebration of the 75th anniversary of the Annual Conference, TEI has organized several special events designed to give participants a quintessential New York experience, such as pizza and architectural tours. These will be held before the conference begins.
The Annual Conference will feature a comprehensive program with nearly 40 sessions focused on U.S. federal, international and state and local tax, as well as Canadian tax, financial reporting and corporate tax management issues. In addition to this high-value content, the event will offer multiple opportunities to meet and connect with your fellow in-house tax professionals during networking breaks and social functions, visit with sponsors and speakers in the exhibit halls and sponsor events, and enjoy everything New York City offers!
For more information, please visit the event page.