Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III and Mike Le co-authored “Sunny State Shade: Arizona’s Objection to California’s Tax Reach” in a recent edition of SeeSALT Digest, by Tax Notes State. In this article, Carley, Robert and Mike evaluate and provide an update on Arizona’s judicial objection to…
The California Department of Tax and Fee Administration held an Interested Parties Meeting to address proposed regulation 1684.5 on marketplace sales. The proposed regulation defines terms used in the Marketplace Facilitator Act (added by AB 147), explains the registration requirements for marketplace facilitators and marketplace sellers, clarifies when a marketplace…
There were two competing bills regarding tax sharing agreements (TSAs) this legislative session: SB 531 and SB 485. The former would have barred all TSAs at the local level as of January 1, 2020. The latter would not bar TSAs but instead would require the locality to report certain information…
Yesterday, the California Franchise Tax Board convened a public meeting to discuss tax compliance within the growing gig economy and the challenges of meeting these obligations. Speakers from academia, the FTB, the business community, and gig workers themselves, discussed various tax issues, three of which stood out. First, California’s nonconformity…
On Sept. 30-Oct. 2, members of Pillsbury SALT will lead discussions at COST’s property tax workshop in Las Vegas. This event aims to bring multistate property tax professionals together and discuss timely legislative and litigation updates, trends and opportunities to make sure your business’s property is not over taxed. Topics…
The California Office of Tax Appeals (OTA)—in a 3-0 pending precedential opinion granting the Appeal of Jali, LLC—has rejected the Franchise Tax Board’s (FTB) 0.2 percent ownership threshold as the new bright-line standard for determining whether an out-of-state LLC member is actively “doing business” (and thereby required to file and…
The Fifth Appellate District of the California Court of Appeal has struck another blow to taxpayers claiming California unconstitutionally discriminates against interstate commerce by permitting intrastate unitary businesses to file using either a combined reporting method or separate accounting method, while requiring interstate unitary businesses to file under the combined…
(This article originally was published by Law360 on August 21, 2019.) The repercussions of the California Supreme Court’s August 2017 opinion in California Cannabis Coalition, et al. v. City of Upland, et al.1 continue to reverberate, leading San Francisco’s business taxpayers to wonder what practical precautions to consider. In a February article, we analyzed…
(This article originally was published by Law360 on July 22, 2019.) On July 5, the San Francisco Superior Court issued a pair of rulings in favor of the city and county of San Francisco, finding that two local special taxes introduced by voter initiatives were valid even though they passed…
On July 23-24, members of Pillsbury SALT will lead discussions at COST’s much anticipated state and local tax technology workshop in Foster City, Calif. This one-and-a-half day event promises to deliver in-depth state and local tax content tailored to technology businesses—everything from startups to long established companies. The varied presentations…