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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.https://seesalt.pillsburylaw.com/files/2020/05/250px-Seal_of_California.svg_.png

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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.image-removebg-preview-5-298x300 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.

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Pillsbury SALT is excited to welcome Lauren Durborow to the team!

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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.

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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.

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