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Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on “Convenience of the Employer” Rule

The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take credits for tax paid to other states while working from Connecticut during the pandemic.  Connecticut law currently allows credits for tax paid to another state only if: (1) the individual was…

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TEI’s Wisconsin Chapter Meeting

Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18. The webinar will begin at 1:00pm CT and feature the following presentations: Market Based Sourcing: Developing a Multistate Approach (Carley Roberts & Nicole Boutros) SALT Implications of…

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How to Be Reasonable When Reasonably Approximating the Market: Part I

Partner Carley Roberts and counsel Robert Merten III authored Part 1 of a multi-part series in Tax Notes State’s SeeSALT Digest to review the landscape of market-based sourcing rules and provide an in-depth focus on various states’ use of reasonable approximation. Read more here.

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Should San Francisco Taxpayers File Protective Claims for Recovery of the Homelessness Tax and the Commercial Rents Tax?

In 2018, San Francisco voters approved, by simple majority vote, two new gross receipts taxes: the Homelessness Gross Receipts Tax (SF-HT) and the Commercial Rents Tax (SF-CRT), with both taxes effective as of January 1, 2019.[1] Because these taxes fund specific governmental services, they are designated as special taxes (specifically,…

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New York Law Raises Property Tax Issues for the U.S. Nuclear Industry

Nuclear fuel storage facilities have been impacted by a change in New York law, which requires facilities located at permanently shut down nuclear power plants to be assessed as real property for ad valorem tax purposes, leading to potential larger, national impacts. SALT team members Zachary T. Atkins, Breann E.…

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California Alliance of Taxpayer Advocates Annual Conference

Pillsbury SALT partner Breann Robowski will present during the California Alliance of Taxpayer Advocates Annual Conference taking place February 11-12, 2021. Breann is partnering with Troy Van Dongen (McDermott Will & Emery) and George Seikaly (San Diego County) to present on the topic, “Streamlining the AAB Process – Remote Hearings,…

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Transfer Tax and Distressed Real Estate: New York and California

Real Estate markets in major cities have taken a hit given the events of the past year. In the latest Swimming Lessons Series presentation,  SALT partner Craig Becker and Real Estate partner Andrew Weiner explore the intersection of transfer tax and enforcement in New York and California. Explore this topic…

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Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity

A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions for members of federal consolidated groups, holding that the policy violated the Uniformity Clause of the state constitution. Verisign, Inc. v. Director of Revenue, No. N19C-08-093 JRJ (Del. Super. Ct. Dec. 17, 2020).…