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Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection

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…

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2023 Wichita Property Tax Conference

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,…

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A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain “Qualified Tangible Personal Property”

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…

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New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts from ADSL and Fiber Broadband Sales

  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)…

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No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit

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…

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Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based Sourcing

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…

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2023 COST Intermediate/Advanced State Income Tax School

Pillsbury SALT attorney Evan Hamme will be presenting at the 2023 COST Intermediate/Advanced State Income Tax School on May 8 in DFW Airport, Texas. 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…

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COST/CTC Mid-West Regional State Tax Seminar

Pillsbury SALT attorneys Carley Roberts, Craig Becker, Zachary Atkins and Kristen Sharp will be presenting at the upcoming COST/CTC Mid-West Regional State Tax Seminar on Wednesday, May 3 in Rolling Meadows, Illinois. Pillsbury and BDO will be sponsoring the seminar which will present updates on significant state tax issues with…

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Property Tax Rate Dispute Merits California Supreme Court Review

For years, some California counties have been imposing disproportionately higher property tax rates on centrally assessed property despite the state constitutional mandate that this property be assessed like locally assessed property. In a challenge brought by centrally assessed utilities, the California Court of Appeal conceded that the higher property tax…