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.…
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…
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…
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. Join Jeff for an evening of conversation and continuing education focused on mental wellness and sustainability in legal practice. The evening will…
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. Carley Roberts – State Tax Spotlight: Washington and Maryland’s Digital Tax Overhaul Tuesday, March 3 Two states are leading the charge in redefining how digital…
SALT partners Craig Becker and Robert P. Merten III will be presenting at this year’s CalTax Annual Meeting. Robert will be speaking on February 23, 2026 on “Legal Ethics.” Craig will be presenting on February 24, 2026 on the topic “California Property Tax and Transfer Tax.” For more information and…
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…
SALT partner Breann Robowski will be presenting at the Western States Petroleum Association 2026 PSAC Conference. Breann will be discussing legal developments regarding the treatment of intangibles. For more information or to register, please visit the event page.
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 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…