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New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing

The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source service receipts to New Jersey.  In its unpublished April 11, 2024, opinion, the…

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COST’s 2024 SALT Workshop for Technology Companies

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)…

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2024 Wichita Property Tax Conference

Pillsbury SALT partner Breann Robowski will present at this year’s Wichita Property Tax Conference. Breann will present on the topic “Legal Update.” Held at Wichita State University, the Wichita Property Tax Conference is the world’s longest lasting and most well-attended conference for both newcomers and advanced professionals involved with complex…

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California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization

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…

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COST’s 2024 Intermediate/Advanced State Income Tax School

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,…

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Proposed Initiative to Amend San Francisco Business Taxes

A proposed initiative (available here) is being circulated to place on the November 5, 2024 ballot, an ordinance amending the Business and Tax Regulations Code effective January 1, 2025. The proposal would initially decrease total business taxes by almost $100 million a year making it one of the biggest tax…

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New Jersey Issues Guidance on Adoption of Federal Partnership Audit Regime

On April 5, 2024, the New Jersey Division of Taxation issued guidance discussing New Jersey’s adoption of the federal centralized partnership audit regime enacted as part of the federal Bipartisan Budget Act of 2015, P.L. 114-74. The guidance was released over a year after the Senate and General Assembly of…