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32nd Annual Paul J. Hartman State & Local Tax Forum

Pillsbury SALT partners Carley Roberts, Zachary Atkins and Aruna Chittiappa will be presenting at the 32nd Annual State and Local Tax Forum taking place Oct. 27–29, 2025. This Forum provides industry, practitioners and state revenue employees the opportunity to participate in a quality forum exploring significant national developments and trends…

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Sourced and Settled: California FTB Finalizes its Long-Awaited Market-Sourcing Regulation, Applicable to Tax Year 2026 and Beyond

After nearly a decade in development, the California Franchise Tax Board (FTB) has finalized its amended market-based sourcing regulation under Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property. The regulation was approved by the Office of Administrative Law and filed with the Secretary of…

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COST 56th Annual Meeting

Join Pillsbury SALT partners Zachary Atkins and Evan Hamme for their presentations at COST’s 56th Annual Meeting. On September 18, Zack will join fellow panelists to discuss the topic, “Deep Dive into COST of Performance and Market-Based Sourcing: Methods of Multistate Analysis, Planning and Tax Accounts.” This session will provide…

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California Updates Tax Regulations on Technology Transfer Agreements

In a move to untangle the complexities surrounding sales and use tax in technology transfer arrangements, California’s tax regulator has laid out three major proposals. SALT attorneys Jeff Vesely and Richard Nielsen dissect these changes—from adding clarification to introducing rebuttable presumptions—that could dial down uncertainty at the crossroads of sales/use…

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Welcome to Pillsbury SALT, Annie!

Pillsbury SALT is excited to welcome Annie Rothschild to the team! Annie’s experience includes advising clients on complex state and local tax matters, with an emphasis on California corporate income tax controversy. Prior to joining Pillsbury, Annie served as an Attorney III at the California Franchise Tax Board, where she…

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Welcome back to Pillsbury SALT, Annie!

Pillsbury SALT is excited to welcome back Annie H. Huang to the team! Annie’s experience focuses on state and local tax matters, including corporate franchise and income, personal income, sales and use, and gross receipts and other local taxes. Annie brings not only strong legal experience but also a genuine…

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Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals

The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the issuing agency, but its authority extends to setting aside the regulation for that…