Pillsbury SALT attorney Jack Camillo will be speaking at TEI’s 2026 Midyear Conference on March 18.
Not the CAT’s Meow: Ohio Supreme Court Reins in the Continuous Delivery Theory for Situsing Receipts
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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.
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.
2026 ABA-IPT Advanced State Income Tax Seminar
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Pillsbury SALT partner Carley Roberts will be presenting at the 2026 ABA-IPT Advanced State Income Tax Seminar on March 17.
Welcome to Pillsbury SALT, Lauren!
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Pillsbury SALT is excited to welcome Lauren Durborow to the team!
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.
5 Questions with Lauren: Continue Reading ›
Sacramento Young Tax Lawyers Webinar
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SALT attorney Jeff Phang will be presenting at an event hosted by the Sacramento Young Tax Lawyers (SacYTL), in collaboration with the California Lawyers Association – Tax Section.
COST’s SALT in a Digital World Workshop
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SALT partners Carley Roberts, Robert P. Merten III, Aruna Chittiappa and Evan Hamme will be speaking at COST’s Digital Workshop taking place March 2–4, 2026.
CalTax 100th Annual Meeting
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SALT partners Craig Becker and Robert P. Merten III will be presenting at this year’s CalTax Annual Meeting.
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.