SALT partner Evan Hamme will speak at PLI’s Hot Topics in State and Local Tax 2024. During this half-day program, presented by PLI, leading state and local tax practitioners will address the developments and trends currently impacting the state/local tax landscape. Join Evan Hamme and Jessica Morgan (EY) at 9:15am…
SALT partner Carley Roberts will moderate a panel at this year’s ABA-IPT Advanced Sales and Use Tax Seminar. The Advanced Sales and Use Tax Seminar is one of three seminars hosted annually by the Institute for Professionals in Taxation and the ABA Section of Taxation. Featuring practitioners from around the…
A California trial court denied the Franchise Tax Board’s (FTB) motion to vacate and modify the judgment declaring FTB Technical Advice Memorandum (TAM) 2022-01 and FTB Publication 1050 invalid underground regulations adopted in violation of the Administrative Procedure Act. Seeking to limit the scope and effect of the…
The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the partnership’s underlying operations. In the Matter of Greenberg, the taxpayer was a New York resident partner…
Pillsbury SALT associate Taylor Wolff was selected to be a member of the LCLD Pathfinders programs for the class of 2024! Congratulations! Check out the announcement here!
A New York nonresident taxpayer, Edward Zelinsky, recently filed a notice of exception to a Division of Tax Appeals’ (DTA) determination that he must allocate all his wages to New York under the so-called “convenience of the employer” rule.[1] Zelinsky, a Connecticut resident who had previously challenged New York’s controversial…
The California Office of Tax Appeals (OTA) recently issued two opinions addressing the burden of proof taxpayers must meet to substantiate entitlement to California’s research and development (R&D) tax credit for qualified expenditures under California Revenue and Taxation Code section 23609. In both opinions, the OTA ruled in favor of…
The SALT team would like to extend our congratulations to Zachary Atkins and Evan Hamme on their promotions to Partner!
A California trial court granted summary adjudication in the American Catalog Mailers Association’s (ACMA) action against the Franchise Tax Board (FTB), invalidating FTB guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes. This follows the court’s denial of ACMA’s first motion…
On November 7, 2023, the Supreme Judicial Court of Maine held a taxpayer’s receipts from the performance of pharmacy benefit management (PBM) services should be apportioned using a look-through approach. Specifically, the court held such services receipts should be apportioned to the state where the prescription drug is dispensed by…