In the Appeal of Mather, the California Office of Tax Appeals (OTA) held in a precedential opinion that New York City’s (NYC) Unincorporated Business Tax (UBT) was not a tax “imposed by and paid to another state,” as required to claim the Other State Tax Credit (OSTC), because New York…
SALT attorneys Zachary Atkins, Evan Hamme, Taylor Wolff and Breanna Zagorski will be presenting at the COST Pacific Northwest Regional State Tax Seminar on December 5. This seminar will present an update on significant state tax issues for California, the Pacific Northwest States, and other significant states around the country.…
The California Franchise Tax Board (FTB) announced it has initiated the formal rulemaking process to amend Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property. The proposed changes would apply to taxable years beginning on or after January 1, 2024. The proposed amendments include several…
Pillsbury SALT attorneys Carley Roberts, Jeffrey Vesely, Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present at this year’s SALT Workshop for Technology Companies on August 14 and 15. Zachary Atkins: Escalating Burden of Gross Receipts Taxes and Local Taxes (Including Recent SF Activity)…
Pillsbury SALT attorney Aruna Chittiappa will be presenting at NYU’s Introduction to State and Local Tax conference taking place July 22-23, 2024 in New York. Aruna will be presenting on the topic “Overview of State Corporate Income Taxation.” This session will cover tax base and federal income tax conformity, common…
The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently rejected by the Office of Tax Appeal’s (OTA) decision in the Matter of the Appeal of Microsoft…
Pillsbury SALT partner Robert P. Merten III will participate as an instructor in the 2024 Summer Tax Institute put on by the UC Davis School of Law. The 34th annual Summer Tax Institute, scheduled for June 17-20, 2024, is an intensive, four-day educational program for tax professionals. The institute has…
Pillsbury SALT partner Evan Hamme will be presenting at COST’s 2024 Intermediate/Advanced State Income Tax School on May 20. Evan, along with Trevor Mauck (Baker & McKenzie), will be presenting on the topic “Filing Methodologies.” This session will cover the various income tax filing methodologies used by the states,…
The California Office of Tax Appeals (OTA), in a decision marked “not precedential” in the Matter of the Appeal of Microsoft Corporation & Subsidiaries, held 100 percent of repatriated dividends under the Tax Cuts and Jobs Act (TCJA) must be included in the taxpayer’s sales factor denominator. First, the OTA…
SALT partners Zachary Atkins and Evan Hamme will speak at COST’s upcoming Spring Conference. This three-and-a-half day conference will bring multistate tax professionals together and will provide updates on key SALT issues and insights regarding state tax trends and opportunities. Join Zack and Evan as they speak on the following…