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California Lawyers Association Tax Policy Seminar

Pillsbury SALT partner Robert P. Merten III will present at a tax policy seminar hosted by the California Lawyers Association on October 18. Robert will be presenting on the topic, “California’s Approach to the Multistate Tax Base.” This program will examine California’s approach to determining the multistate tax base, including…

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Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs

The Arizona Court of Appeals held that an investment tax credit (ITC) deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property tax purposes.  In so holding, the court rejected the argument that an ITC has…

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Technology Transfer Agreements: Latest Developments in California

In 1993, the California Legislature amended Revenue and Taxation Code (RTC) sections 6011 and 6012 to exclude from California sales and use tax amounts charged for intangible personal property transferred with a technology transfer agreement (TTA) if the TTA separately stated a reasonable price for the tangible personal property (TPP). Nine…

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Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity

The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carve-out language regarding the term “unitary corporation.” Taxpayer Apache Corporation’s (Taxpayer) foreign subsidiaries issued dividends, generated Subpart F income, or otherwise…

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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  In its unpublished April 11, 2024, opinion, the…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…