The Pillsbury SALT team had an incredible time last month at the COST SALT Workshop for Technology Companies in Cupertino, CA. Carley Roberts, Zachary Atkins, Craig Becker, Evan Hamme, Robert P. Merten III, Jeffrey Vesely, and Aruna Chittiappa were all panelists and presented on various topics at the workshop. The…
SeeSALT Blog
Pillsbury SALT recognized in Best Lawyers 2025
Congratulations to our Pillsbury SALT team for earning recognition in the 2025 edition of Best Lawyers in America. Partner Craig Becker was recognized as a Lawyer of the Year in San Jose for Litigation and Controversy – Tax. Congratulations to all recognized! Best Lawyers Craig Becker (Lawyer of the…
Technology Transfer Agreements: Latest Developments in California
In 1993, the California Legislature amended Revenue and Taxation Code (RTC) sections 6011 and 6012 to exclude from California sales and use tax amounts charged for intangible personal property transferred with a technology transfer agreement (TTA) if the TTA separately stated a reasonable price for the tangible personal property (TPP). Nine…
Pillsbury SALT recognized in Legal 500 2024
Congratulations to our Pillsbury Winthrop Shaw Pittman LLP SALT team for earning recognition in the Legal 500 US ranking guide. The California SALT team earned a Band 5 ranking for US Taxes – Contentious. Congratulations!
COST’s 2024 Annual Meeting
Pillsbury SALT attorneys Evan Hamme and Aruna Chittiappa will present during COST’s Annual Meeting on September 25 and 26. Evan Hamme: The Impact of Loper Bright on State Tax Authority and Taxpayer Deference Wednesday, September 25, 11:10 am – 12:00 pm The Loper Bright decision overruled the landmark Chevron doctrine, which had provided a framework for…
CalTax Foundation Webinar
Pillsbury SALT partner Carley Roberts will participate as a panelist on an upcoming CalTax Foundation webinar on Tuesday, September 10. Join Carley as she presents on the topic, “Mass Appeal: Notable Decisions and Trends at the Office of Tax Appeals.” The panelists will discuss and provide updates on recent notable…
Pillsbury SALT recognized in Chambers USA 2024
Congratulations to our Pillsbury SALT team, again earning recognition in the Chambers USA ranking guide. Our California SALT team earned a Band 1 ranking for the 4th year, with partners Jeffrey Vesely (Band 1) earning his 18th ranking, Carley Roberts (Band 1) with her 16th ranking, and Robert Merten (Band 2) with…
Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity
The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carve-out language regarding the term “unitary corporation.” Taxpayer Apache Corporation’s (Taxpayer) foreign subsidiaries issued dividends, generated Subpart F income, or otherwise…
New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing
The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source service receipts to New Jersey. In its unpublished April 11, 2024, opinion, the…
Tennessee Taxpayers Could Reap Billions in Past and Future Tax Savings
Zack Atkins’ comments in Law360 Tax Authority regarding newly passed legislation in Tennessee that could provide taxpayers with up to $1.6 billion in rebates for portions of three years of past payments and up to $400 million in new savings each year. Read more here.