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…
Articles Posted in Issues
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)…
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…
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…
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…
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…
TEI New York Chapter SALT Meeting
Pillsbury SALT attorneys Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present during TEI’s New York Chapter SALT Meeting on April 19 taking place at Pillsbury’s New York Office. Pillsbury SALT is pleased to share three presentations at the April meeting: SALT Cases Impacting…
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…
UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms
In addition to the tax relief announced in January, the California Franchise Tax Board (FTB) has automatically extended the income tax filing and payment deadlines for businesses and individuals affected by severe winter storms in California until October 16, 2023. The tax relief now applies to businesses and residents…
CalTax 97th Annual Meeting
Pillsbury SALT partner Carley Roberts will be presenting at California Taxpayers Association’s 97th Annual Meeting on March 23. Carley will be participating in a panel discussion on the topic “Taxation of the Digital World.” The panel will delve into the implications of an increasingly digital world and how state and…