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New Tax Legislation Shifts Consolidated Return Landscape in Georgia

Pillsbury SALT attorneys Zachary T. Atkins, Evan M. Hamme, Jack Thomas Camillo discuss new tax legislation in GA. Takeaways For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of…

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2022 CalTax Foundation Webinar Series

Pillsbury SALT partner Breann Robowski will participate in the CalTax webinar series on June 7. Breann is partnering with Cris O’Neall (Greenberg Traurig) and Richard Ayoob (Ajalat, Polley, Ayoob, Matarese & Broege) to present on the topic, “Is Due Process Possible in Remote Assessment Appeals Hearings?” The speakers will discuss…

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Broker-Dealer Successfully Fights Look-Through Sourcing in New York

An administrative law judge in the New York State Division of Tax Appeals rejected the New York State Division of Taxation’s use of a look-through approach for sourcing fees paid to a broker-dealer for marketing, recordkeeping, and support services.  The April 28, 2022 determination in Matter of TD Ameritrade, Inc.,…

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Texas Supreme Court Sides with Sirius XM’s “Straightforward” Interpretation of Service Receipt Sourcing Statute

The Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision resolves disagreement regarding the proper interpretation of a Texas franchise tax apportionment statute that addresses the…

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2022 ABA/IPT Virtual Advanced Tax Seminars

Pillsbury SALT partner Breann Robowski will present during the 2022 ABA/IPT Virtual Advanced Tax Seminars in March. The Institute for Professionals in Taxation and the ABA Section of Taxation will once again host three jointly sponsored seminars in Sales Tax, Property Tax, and State Income Tax. These seminars will feature…

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Contractual Delivery Terms Control Application of Alabama’s Wholesale Oil License Fee

The Alabama Tax Tribunal held the taxpayers’ wholesale sales of fuel that entered and exited the state via the Colonial Pipeline were subject to the state’s wholesale oil license fee. The sales in question were made to Alabama license holders and involved fuel imported from out-of-state. The fuel would either…

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COST’s 2022 Sales Tax Conference & Audit Session

Pillsbury SALT partner Carley Roberts will present at COST’s 2022 Sales Tax Conference & Audit Session on March 10. Carley is partnering with Mark Loyd (Dentons) to present on the topic, “Defending Against States’ Use of Deference, Substance Over Form, & Sham Transaction Doctrines.” State Tax Administrators have pushed the use…