The New York State Tax Appeals Tribunal (TAT) issued a decision that addresses sourcing “services” vs. the catch-all “other business receipts” for years prior to New York Tax Reform (tax years beginning prior to 1/1/2015). The TAT found that the taxpayer, who provided electronic litigation support to its clients, was…
Articles Posted in Issues
Presenting at the COST State and Local Tax Workshop for Technology Companies
After a successful SALT Retreat in Napa, Calif., the team headed to Foster City to present on topics at the COST State and Local Tax Workshop for Technology Companies. Carley Roberts, Craig Becker and Jeffrey Vesely spoke on a variety of topics including an overview of new and established local taxes…
The 5 Supermajority Tax Challenges Facing California
(This article originally was published by Law360 on July 22, 2019.) On July 5, the San Francisco Superior Court issued a pair of rulings in favor of the city and county of San Francisco, finding that two local special taxes introduced by voter initiatives were valid even though they passed…
COST’s Inaugural 2019 State and Local Tax Workshop for Technology Companies
On July 23-24, members of Pillsbury SALT will lead discussions at COST’s much anticipated state and local tax technology workshop in Foster City, Calif. This one-and-a-half day event promises to deliver in-depth state and local tax content tailored to technology businesses—everything from startups to long established companies. The varied presentations…
Gross! Portland, Oregon, Targets Large Retailers with New Gross Receipts Tax
As of January 1, 2019, large retailers doing business in Portland, Ore., are subject to a new 1% gross receipts tax dubbed the “Clean Energy Surcharge.” This new tax is imposed on all businesses subject to the Portland business license tax that have annual retail receipts of over $1 billion…
The Evolution of Software as a Service Taxes Post-Wayfair
(This article originally was published by Law360 on May 17, 2019.) In the last year, several state legislatures have enacted laws and several state courts have published decisions on whether software as a service, or SaaS, is subject to sales and use tax. These developments impact many SaaS providers, especially…
“California Municipal Gross Receipts Taxes”
Craig A. Becker presents “California Municipal Gross Receipts Taxes” at the Palo Alto Chamber Business Connections Group event.
“The Taxation of Section 965 Deemed Repatriation”
Carley Roberts presents on “The Taxation of Section 965 Deemed Repatriation” at COST’s Spring Audit Session & Income Tax Conference 2019 on May 1.
California Governor Signs Marketplace Facilitator Legislation, Preview to New Rules
TAKEAWAYS New legislation sets California’s sales and use tax economic nexus threshold to $500,000. New legislation creates Marketplace Facilitator Act, statutorily defining marketplace facilitators as retailers and sellers. On April 25, 2019, California enacted comprehensive marketplace facilitator legislation. Many said last fall this would be an impossible feat given the…
California Business Tax May Provide High Court Nexus Test
(This article was originally published by Law360 on April 16, 2019.) In recent years, many have openly criticized California for its income tax litigating position involving out-of-state companies that hold passive, minority interests in pass-through entities doing business in California. The state argues these out-of-state companies are doing business in California…