Articles Posted in Market-Based Sourcing

Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III, Jeff Phang, and Lexi Louderback recently published “How to Be Reasonable When Reasonably Approximating the Market: Part II”  in Tax Notes State. Read more here.

Pillsbury Special Counsel Zack Atkins was recently quoted in Tax Notes State and Law360 discussing the challenges presented by market-based sourcing. Read more here.

Pillsbury SALT attorney Zachary Atkins will present “Market-Based Sourcing, the Continuing Conundrum” during the 28th Annual Paul J. Hartman State and Local Tax Forum on October 28. The Professor Paul J. Hartman Memorial State and Local Tax (SALT) Forum, sponsored in conjunction with the Vanderbilt University Law School, provides industry, practitioners and…

In One Technologies LLC v. Franchise Tax Board, an out-of-state California corporate taxpayer filed suit in California trial court challenging the state’s mandatory single sales factor apportionment formula on the basis its passage in 2012 via voter initiative Proposition 39 unconstitutionally violated the “single subject rule.” Prior to 2013, most…

Five years and six interested parties meetings later, California is finally ready to proceed with the formal rulemaking process to adopt substantial amendments to its market-based sourcing rules.  At the Franchise Tax Board’s September 9, 2021 meeting, FTB staff requested permission and received approval from its three-member Board to commence…

Pillsbury SALT attorneys Carley Roberts, Annie Huang and Robert Merten III will present at the COST Central West Regional State Tax Webinar on March 24. They will present on the topic, “California Market-Based Sourcing Issues.” For more information and to register, please click here.

Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18. The webinar will begin at 1:00pm CT and feature the following presentations: Market Based Sourcing: Developing a Multistate Approach (Carley Roberts & Nicole Boutros) SALT Implications of…

Partner Carley Roberts and counsel Robert Merten III authored Part 1 of a multi-part series in Tax Notes State’s SeeSALT Digest to review the landscape of market-based sourcing rules and provide an in-depth focus on various states’ use of reasonable approximation. Read more here.

Pillsbury SALT partner Annie Huang will present during COST’s 51st Annual Meeting on October 22. Partnering with Robert Johnson (Crowe), Eran Liron (PwC) and Ruben Sislyan (Greenberg Traurig), Annie will present “Market Sourcing through Alternative Apportionment or Creative Characterizations of Activity,” moderated by Stephanie Do (COST). Few issues have created…

Pillsbury SALT was proud to present TEI/IPT Silicon Valley’s State and Local Tax Day & IPT Joint Meeting on December 5! The team presented a 3/4-day seminar that focused on topics related to the State and Local Tax implications of the Tax Cuts and Jobs Act, the U.S. Supreme Court’s…