Close

SeeSALT Blog

Updated:

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…

Updated:

Press Mention: Aruna Chittiappa Analyzes New York Tax Case Poised to Shape SALT Law

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…

Updated:

Press Mention: New York Tied to Narrowed Scope of Federal Corporate Transparency Act

In a recent article published by TaxNotes, our colleague Andrew Weiner commented on New York Governor Kathy Hochul’s veto of legislation that would have decoupled the state’s LLC Transparency Act from the federal Corporate Transparency Act. The veto keeps New York’s beneficial ownership disclosure regime aligned with the narrowed federal…

Updated:

California’s Amended Wealth Tax Initiative Meets Five New Foes

Proponents of the 2026 Billionaire Tax Act amended the initiative, prompting opponents to file five new initiatives aimed at undermining various aspects of the measure. The 2026 Billionaire Tax Act would impose a one-time wealth tax on California residents and trusts with “net worth,” defined in the initiative, exceeding $1…

Updated:

California Alliance of Taxpayers Advocates Annual Conference

SALT partner Breann Robowski will be speaking at the California Alliance of Taxpayer Advocates 2025 Annual Conference on December 12. Breann will be discussing legal updates at this year’s annual conference, which is being held at the The Ritz-Carlton, Laguna Niguel. For more information and to register, please visit the…

Updated:

New York City Initiates Rulemaking Process for Business Corporation Tax

New York City’s Department of Finance (DOF) has issued the first tranche of proposed regulations under new Chapter 11A of Title 19 of the Rules of the City of New York (Proposed Rules) to implement its 2015 corporate tax reform—moving straight into formal rulemaking, in contrast with State’s multi-stage drafting…

Updated:

Billion-Dollar Question: California Initiative Targets the Ultra-Wealthy with One-Time Tax

  Proponents have filed a California ballot initiative proposing a one-time wealth tax on individuals with more than $1 billion in net worth. The “2026 Billionaire Tax Act” would impose, for tax year 2026, a 5% tax on “all forms of personal property and wealth, whether tangible or intangible” exceeding…

Updated:

2025 Annual Meeting of the Tax Bar and Tax Policy Conference

Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III and Jeff Phang will be presenting at this year’s Annual Meeting on November 12–14, 2025. Robert P. Merten III: Nuts and Bolts Bootcamp Wednesday, November 12 This workshop is designed specifically for law students and younger tax attorneys looking to gain a…