A California trial court denied summary judgment in the American Catalog Mailers Association’s (ACMA) action that seeks to invalidate Franchise Tax Board (FTB) guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes. However, the court signaled it may invalidate the FTB’s…
Pillsbury attorneys Carley Roberts, Zachary Atkins, and Evan Hamme will present at COST’s 54th Annual Meeting in Las Vegas, NV. Zack is partnering with Dorothy Lo (PwC), Nathan Runyan (Holland & Hart LLP), and Chris Wilson (Holland & Knight LLP) on October 18 to present on the topic, “The Sales Taxation…
Congratulations to our Pillsbury SALT team for earning recognition in the 2024 edition of Best Lawyers in America and Best Lawyers: Ones to Watch. Partner Jeffrey Vesely was recognized as a Lawyer of the Year in San Francisco for Litigation and Controversy – Tax. Congratulations to all recognized! Best…
On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey’s Corporation Business Tax (CBT). The bill enacted a variety of clarifications, corrections and modifications to the CBT. The bill includes substantive amendments to CBT provisions, such as: Economic Nexus Threshold: The bill…
The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales terms obtained from Minnesota customers by the company’s salespeople. PL 86-272 is a federal law enacted in 1959 that…
Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25. Breann will be partnering with David Crapo (Crapo Deeds) for a “Legal Update – Legislative Lightning Round” session at the Wichita Property Tax Conference that provides valuation and assessment topics for complex industries,…
Pillsbury SALT attorneys Zachary Atkins, Craig Becker, Carley Roberts, & Richard Nielsen discuss California Assembly Bill 52. AB 52 would provide corporation and personal income tax credits for local sales and use and district taxes paid on machinery and equipment primarily used in manufacturing, research and development, electric power generation…
An administrative law judge with the New York State Division of Tax Appeals held that the federal Internet Tax Freedom Act (ITFA) preempted the imposition of New York franchise tax and a metropolitan transportation business tax (MTA) surcharge on gross receipts from sales of asymmetric digital subscriber line (ADSL)…
The California Office of Tax Appeals (OTA) held a California resident was not entitled to claim an other state tax credit (OSTC) for taxes paid to Massachusetts because gain from the sale of an LLC membership interest was wholly sourced to the taxpayer’s domicile under California law. The taxpayer contended…
On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes. In Billmatrix Corp. v. State of Florida, Department of Revenue, No. 2020-CA-000435 (Fla. 2d Cir. Ct. Mar. 1, 2023), the court…