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…
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…
Pillsbury SALT associate Breanna Zagorski will be presenting at the 2025 TEI Annual Conference on Oct. 28, 2025. Breanna will be presenting on the topic “From Cloud to Checkout: Navigating SALT in the Digital Marketplace.” TEI’s 80th Annual Conference is the must-attend event of the year for all in-house tax…
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…
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…
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…
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…
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…