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.
TEI’s 2026 Midyear Conference
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
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
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!
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

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
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
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

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
SALT partner Breann Robowski will be presenting at the Western States Petroleum Association 2026 PSAC Conference.



