In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by prematurely using reasonable approximation to source the income of a multistate unitary business. During the tax year…
A Maryland state court struck down the state’s Digital Advertising Gross Revenues Tax (“Digital Ad Tax”) as invalid under both the federal Internet Tax Freedom Act (“ITFA”) and U.S. Constitution. Enacted February 12, 2021, Maryland’s Digital Ad Tax by its terms applies to any person with at least $1 million…
A New Mexico Hearing Officer found that Gross Receipts Tax does not apply to a taxpayer’s markup for services performed outside New Mexico, but the taxpayer’s reimbursements for payroll to New Mexico employees are taxable New Mexico receipts. In Protest of Talbridge, the taxpayer was a Texas employment agency with…
The SALT team briefs the outcomes of the first meeting of the Multistate Tax Commission (MTC). Read More: Model Receipts Sourcing Regulations Work Group’s Curious First Meeting(pillsburylaw.com)
Pillsbury SALT partner Carley Roberts will be presenting at the Annual Meeting of the California Tax Bar and California Tax Policy Conference on November 3. The Annual Meeting of the California Tax Bar and California Tax Policy Conference will be taking place in San Diego and features an agenda of…
The American Catalog Mailers Association (ACMA), which describes itself as the nation’s leading industry trade association advocating for catalog, online, direct mail, and other remote-selling merchants and their suppliers, has filed suit against the California Franchise Tax Board (FTB) in the San Francisco County Superior Court of California. ACMA’s complaint…
The Pennsylvania Governor signed H.B. 1342 to enact changes to the state’s corporate income tax.[1] The legislation modifies the corporate income tax in three ways: (1) adopts a bright-line economic nexus standard; (2) adopts market sourcing for receipts from intangibles; and (3) reduces the corporate tax rate and gradually continues…
Our federal tax colleagues analyzed the corporate tax provisions in the Inflation Reduction Act, including the 15-percent minimum tax on corporations and the excise tax on stock buybacks. Read More: Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions (pillsburylaw.com)
Pillsbury partners Breann Robowski and Jorge Medina will be participating in the Wichita Property Tax Conference taking place on July 24-28. The Wichita Property Tax Conference is an annual conference hosted on the campus of Wichita State University. It is a well-attended conference for both newcomers and advanced professionals involved…
The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s…