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The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s California apportionment formula and is not sourced 100 percent to the nonresident shareholder’s domicile. Continue Reading ›

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Pillsbury SALT is excited to welcome Jack Camillo to the team!

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Jack’s experience includes multistate litigation, planning, audit defense, and controversy issues.

He joins Pillsbury’s New York office as an associate.

5 Questions with Jack:

1. Who inspires you?

I think it’s safe to say my parents inspire me.

2. What drew you to the law?

Research and writing drew me to the law. I found litigation interesting, but I always enjoyed writing for as long as I can remember.

3. What aspect of State and Local Tax law do you find most interesting?

State and Local Tax is constantly changing and allows you to experience a wide variety of topics. Also, it’s interesting to see trends in taxation begin and sweep across the country.

4. How do you re-center yourself?

Usually by spending time with friends or family. As someone who lives in Manhattan, I also find it helpful to get out of the city and into nature.

5. What is your go-to comfort food? Any interesting facts?

My go-to comfort food is probably pizza. I’ve recently gotten into making my own pizza at home.

Little known fact – I’m unable to drive long distances. I probably have a 1-hour window before I fall asleep!

 

 

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Pillsbury SALT is pleased to welcome Taylor Wolff to the team!

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Taylor’s experience includes multistate litigation, planning, audit defense, controversy issues, and mergers and acquisitions.

He joins Pillsbury’s New York office as an associate.

5 Questions with Taylor:

1. Who inspires you?
My mom inspires me. She was a social worker in the Bronx for about 30 years. She treated children, adolescents, and families as a therapist. She was also a substance abuse counselor and worked with people who have been incarcerated in the criminal justice system, as well as those who have been diagnosed with HIV/AIDS. Her commitment to helping those less fortunate instilled in me a strong sense of justice. I remember her taking me to work where I got to meet the attorneys and judges. I was so excited to see the courtrooms and one judge even invited me to sit on the bench!

2. What drew you to the law?
I have a deep desire to help people and was drawn by the fun of distilling complex topics in easy ways that help my clients. I also love to write, and lawyers write a lot!

3. What aspect of State and Local Tax law do you find most interesting?
Laws are always changing in the 50 states, D.C., and myriad of localities across the United States. I like the challenges that come with these changes, and how my work can help businesses and stimulate the economy. I also love the deep underpinning of Constitutional Law and sinking my teeth into a good constitutional argument. SALT is a fun combination of code-based analysis, digging into definitions and statutory construction, and creative Constitutional interpretation.

4. What is your go-to comfort food?
I love sushi and I am a soup enthusiast, especially homemade chicken soup.

5. What do you do for fun? Any hidden talents?
I love to go to comedy shows and live concerts, travel, play board games and cards with friends, and am interested in finance and real estate podcasts/books and mindfulness meditations. My hidden talent is drawing courtroom caricatures!

 

 

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Pillsbury SALT attorneys Zachary T. AtkinsMarc A. SimonettiEvan M. HammeJack Thomas Camillo discuss new tax legislation in GA.

Takeaways https://seesalt.pillsburylaw.com/files/2022/05/Georgia-StateSeal.svg_-300x300.png

  • For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of Revenue.
  • The principal benefit of filing a consolidated return is the ability to offset taxable income and losses.
  • The election is irrevocable and binding for five years.

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An administrative law judge in the New York State Division of Tax Appeals rejected the New York State Division of Taxation’s use of a look-through approach for sourcing fees paid to a broker-dealer for marketing, recordkeeping, and support services.  The April 28, 2022 determination in Matter of TD Ameritrade, Inc., confirms that such fees are properly sourced to the location of the customer responsible for payment, in this case two banks. https://seesalt.pillsburylaw.com/files/2020/04/Seal_of_New_York.svg_-300x300.png

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Pillsbury SALT Counsel Evan Hamme will be an instructor at the COST Intermediate and Advanced Income Tax School scheduled for May 15-19, 2022.cost-300x90

COST’s Intermediate and Advanced Income Tax School is being held simultaneously with COST’s SALT Basics School and Intermediate and Advanced Sales and Use Tax School in Atlanta, GA.  These programs provide learning opportunities for attendees to explore and gain a deeper understanding of SALT Income and Sales and Use Tax issues. Continue Reading ›

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