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…
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…
Pillsbury SALT partner Carley Roberts will participate as a panelist on an upcoming CalTax Foundation webinar on Tuesday, September 10. Join Carley as she presents on the topic, “Mass Appeal: Notable Decisions and Trends at the Office of Tax Appeals.” The panelists will discuss and provide updates on recent notable…
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…
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 In its unpublished April 11, 2024, opinion, the…
Zack Atkins’ comments in Law360 Tax Authority regarding newly passed legislation in Tennessee that could provide taxpayers with up to $1.6 billion in rebates for portions of three years of past payments and up to $400 million in new savings each year. Read more here.
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 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…
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…