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California Groups File Signatures for Initiative to Curtail Local Taxes

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…

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TEI’s 2026 Midyear Conference

Pillsbury SALT attorney Jack Camillo will be speaking at TEI’s 2026 Midyear Conference on March 18. Jack and his fellow panelists will be speaking on the topic “The Invisible Customer: Navigating State Look-Through Sourcing.” TEI’s Midyear Conference, running from March 15-18, 2026, is the premier event for in-house tax professionals…

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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.…

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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. Carley will be speaking on the topic “Factor Fiction: Navigating Denominator Dilemmas.” With many states shifting to a single sales factor to apportion taxable income, determining what is included in…

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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: 1. Who inspires you? My family (and…

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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…