New York City’s Department of Finance (DOF) has issued the first tranche of proposed regulations under new Chapter 11A of Title 19 of the Rules of the City of New York (Proposed Rules) to implement its 2015 corporate tax reform—moving straight into formal rulemaking, in contrast with State’s multi-stage drafting…
Proponents have filed a California ballot initiative proposing a one-time wealth tax on individuals with more than $1 billion in net worth. The “2026 Billionaire Tax Act” would impose, for tax year 2026, a 5% tax on “all forms of personal property and wealth, whether tangible or intangible” exceeding…
After nearly a decade in development, the California Franchise Tax Board (FTB) has finalized its amended market-based sourcing regulation under Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property. The regulation was approved by the Office of Administrative Law and filed with the Secretary of…
In a move to untangle the complexities surrounding sales and use tax in technology transfer arrangements, California’s tax regulator has laid out three major proposals. SALT attorneys Jeff Vesely and Richard Nielsen dissect these changes—from adding clarification to introducing rebuttable presumptions—that could dial down uncertainty at the crossroads of sales/use…
Pillsbury SALT is excited to welcome back Annie H. Huang to the team! Annie’s experience focuses on state and local tax matters, including corporate franchise and income, personal income, sales and use, and gross receipts and other local taxes. Annie brings not only strong legal experience but also a genuine…
The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the issuing agency, but its authority extends to setting aside the regulation for that…
Pillsbury SALT partner Robert P. Merten III will be participating as a panelist in a CalTax Foundation webinar on August 28. Robert will join fellow panelists for “The Right to Protest: California Tax Agencies’ Protest Resolution Trends and Practices” session, which will explore the evolving landscape of protest resolution within…
Pillsbury SALT attorneys Carley Roberts, Evan Hamme, Aruna Chittiappa and Kristen Sharp will be presenting at COST’s 2025 SALT Technology Workshop on August 13-14. This workshop will cover key SALT issues technology companies (both start-up and established) are facing, such as state taxation of Digital Business Inputs, FITFA, sourcing, apportionment,…
Join Pillsbury SALT attorneys for this live webinar presented by COST. On June 18, Pillsbury SALT attorneys will join COST’s California Corporate Income Tax webinar for a discussion on California corporate income tax issues and San Francisco’s changes to its tax structure. Our attorneys will lead the following sessions: Jeff…
Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January 1, 2025, and would align California tax law with numerous federal provisions…