Breann serves as an innovator and significant contributor at the California State Board of Equalization (BOE) meetings. She has testified at length at each of the BOE’s monthly meetings since September 2020 as a member of the Collaborative Workgroup on Remote Hearings—the task force created by the BOE to pioneer the implementation of virtual Assessment Appeals Board (AAB) hearings as an alternative to in-person hearings due to the safety concerns and conditions associated with the COVID-19 pandemic. Continue Reading ›
A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions for members of federal consolidated groups, holding that the policy violated the Uniformity Clause of the state constitution. Verisign, Inc. v. Director of Revenue, No. N19C-08-093 JRJ (Del. Super. Ct. Dec. 17, 2020). The decision presents a potential refund opportunity for Delaware corporate taxpayers who were members of a federal consolidated group, and for Delaware corporate income tax purposes had their separate-company NOL deductions limited to the group’s consolidated NOL.
Pillsbury attorneys Marc Simonetti, Zack Atkins and Caroline Koo explain.
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Pillsbury SALT partners Craig Becker and Breann Robowski will present during Pillsbury’s 2021 California CLE Marathons. This event features a wide variety of live webinars on timely topics. Craig and Breann will present “California Property, Transfer and Local Tax Updates” on Monday, January 25. Continue Reading ›
Pillsbury SALT partners Breann Robowski and Marc Simonetti will present during The National Multistate Tax Symposium. The theme for the 2021 symposium is “Leading Through Uncertainty – Navigating Multistate Tax With Confidence,” which will focus on exploring significant issues facing today’s multistate tax practitioners.
A federal district court held that under comity principles, Indiana state court is a more appropriate venue for a putative class action brought by three Indiana municipalities seeking to impose franchise fees on a group of online video providers. Order, City of Fishers v. Netflix, Inc. No. 1:20-cv-02351-JMS-MPB (S.D. Ind. Nov. 18, 2020). The federal district court remanded the case to the Marion Superior Court, where it was originally filed.
Pillsbury SALT is excited to welcome Senior Law Clerk, Melissa Libutti to our team! Melissa focuses on tax controversy, from audit defense through litigation, and also counsels on multistate tax planning and structuring matters. Melissa previously clerked for Pillsbury during Law School at Fordham University and we are thrilled to have her on the team permanently. She will join our New York-based team.
Pillsbury SALT is pleased to share three presentations during TEI Chicago’s SALT Program on December 8 via webinar. Partners Carley Roberts, Jeff Vesely, Annie Huang and Marc Simonetti will partner with Mark Fadden to present timely SALT content. Continue Reading ›
Pillsbury SALT is proud to announce its inclusion in the U.S. News – Best Lawyers 2021 “Best Law Firms” survey. Pillsbury’s Tax team earned a National Tier 1 Ranking in Tax Litigation and Tax Law, Tier 1 in San Francisco for Tax Litigation and Tax Law, Tier 2 in Tax Law for New York City, and Tier 1 in Tax Law in Miami. Pillsbury has earned a total of 162 national and regional practice rankings in the latest U.S. News – Best Lawyers 2021 “Best Law Firms” survey. Of those rankings, 27 were listed as national Tier 1 and 63 were listed as Tier 1 within their respective metropolitan markets.
On November 3, California and San Francisco voters were asked to decide several tax‑related referenda with major implications across all business industries. Although it is too early to state with certainty, voters appear to have rejected Proposition 15, a measure that would introduce a so-called “split roll” property tax system. On the same day, voters in San Francisco overwhelmingly approved a battery of tax-related measures: Proposition F, which overhauls San Francisco’s business taxes; Proposition I, which doubles the real estate transfer tax on transactions exceeding $10 million; Proposition L, which institutes an aggressive new “Overpaid Executive Gross Receipts Tax;” and Proposition J, which repeals and replaces an annual parcel tax.
Pillsbury attorneys Craig Becker, Breann Robowski, and William Bennett explain.
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The fate of Washington’s Business & Occupation (“B&O) surtax on large financial institutions remains uncertain as the state’s highest court has not yet decided whether to grant direct review or transfer the state’s appeal to the Washington Court of Appeals. On July 13, 2020, the State of Washington filed a direct appeal in the Washington Supreme Court seeking to overturn a trial court decision that struck down the state’s recently enacted surtax on large out-of-state financial institutions. Wash. Bankers Ass’n v. State, No. 19-2-29262-8 SEA (Wash. Super. Ct. May 15, 2020), appeal docketed, No. 98760-2 (Wash. July 13, 2020). On July 27, 2020, the state filed its statement of grounds for direct review with the Washington Supreme Court and on August 24, 2020, the respondents, the Washington Bankers Association and American Bankers Association (collectively, the “Associations”) filed their answer. Continue Reading ›