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…
On January 10, 2025, California Governor Gavin Newsom released his January Budget Proposal for the 2025 – 2026 fiscal year. Notably, Governor Newsom’s budget would increase tax revenue by requiring banks and financial corporations to move from an equally weighted three-factor formula, comprising property, payroll and sales factors, to a single-sales-factor formula…
The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs). On January 22, 2025, the CTIA (formerly the Cellular Telecommunications and Internet Association) submitted comments. The California Taxpayers Association…
SALT partner Jeffrey Vesely will be presenting at CalTax’s 99th Annual Meeting on March 6. Jeff and co-panelists Marcy Jo Mandel (McDermott Will & Emery) and Jenica Wilkins (Ernst & Young LLP) will be discussing “California Tax Trends.” The panelists will address emerging trends at tax agencies, as well as…
In the Appeal of Mather, the California Office of Tax Appeals (OTA) held in a precedential opinion that New York City’s (NYC) Unincorporated Business Tax (UBT) was not a tax “imposed by and paid to another state,” as required to claim the Other State Tax Credit (OSTC), because New York…
On September 28, 2024, California enacted Assembly Bill 2854, which imposes new disclosure requirements on local agencies (i.e., chartered or general law cities and counties) that have entered into local sales tax sharing agreements with retailers. Generally, pursuant to a local sales tax sharing agreement, a retailer will agree to…