SeeSALT attorneys Carley Roberts & Mike Le partnered with their Pillsbury tax colleagues Nora Burke & Hannah Hollingsworth to detail the impact of COVID-19 on the IRS and States Extended Tax Payment Deadlines. Takeaways of the recent article include: The IRS announced that individuals and businesses may defer both federal…
SeeSALT Blog
Michigan Alternative Apportionment Formula Victory for Taxpayer
A very interesting and heartening decision was just handed down by the Michigan Court of Appeals in Vectren Infrastructure Services Corp. v. Department of Treasury in connection with a sale of an out-of-state business. Copy attached. In Vectren, the Court of Appeals held that the Department of Treasury’s (DOT) removal…
South Carolina ALC Says Pipeline Company’s Assets May Qualify for Pollution Control Equipment Exemption
On March 6, 2020, the South Carolina Administrative Law Court entered an order in Colonial Pipeline Co. v. South Carolina Department of Revenue, No. 18-ALJ-17-0443-CC, in which it held that a pipeline company’s assets may qualify for a property tax exemption for pollution control equipment of industrial plants under S.C.…
New Mexico Court of Appeals Upholds Refund Claim Dismissal for Taxpayer’s Violation of Discovery Order
The New Mexico Court of Appeals decided a case illustrating the heavy risks of failing to comply with a court’s order. Specifically, the Court of Appeals upheld the District Court’s full dismissal of a taxpayer’s refund claim for violating a discovery order. In Bowman v. Manforte, the taxpayer sought a…
Arizona Advances Legislation Requesting Federal Intervention for Sales Tax Simplification
There have been two interesting developments in Arizona as a result of Wayfair. First, the Arizona House of Representatives pushed forward a resolution, H.C.M. 2006, last week to formally ask Congress to enact uniform national legislation to simplify sales tax or similar tax collection by all states and to reduce…
Washington B&O Tax Litigation Hits Financial Services Industry
A Washington state trial judge partially granted the state’s motion to dismiss a lawsuit challenging the validity of a recently enacted Washington tax measure that increases the state’s Business & Occupation Tax (B&O Tax) on large, out-of-state financial institutions. The Plaintiffs, the Washington Bankers Association and American Bankers Association (collectively,…
Massachusetts Supreme Judicial Court Upholds Massachusetts Sales Tax on Screen-Sharing Software Products
The Massachusetts Supreme Judicial Court held that sales tax applied to subscription fees for three online Citrix products, “GoToMyPC,” “GoToAssist” and “GoToMeeting,” which allow users to remotely access other users’ computers. Citrix Systems, Inc. v. Comm’r of Revenue, No. SJC-12741 (Mass. Feb. 5, 2020). In so holding, the Court affirmed…
Illinois Taxpayers Score Rare TIA Win in Property Tax Dispute
On January 29, 2020, the U.S. Court of Appeals for the Seventh Circuit held the Tax Injunction Act did not bar a federal lawsuit challenging property tax assessments on equal protection grounds because the taxpayers that brought the suit did not have a plain, speedy and efficient remedy in the…
No Dealer Here: Walmart Walks Away with Big Marketplace Facilitator Win in Creole State
On January 29, 2020, the Louisiana Supreme Court issued a 4-3 decision in Normand v. Wal-Mart.com USA, reversing in full two lower courts and holding Walmart.com was not required to collect local sales tax on third-party sales facilitated through its online marketplace. The majority concluded Walmart.com was not a “dealer”…
Welcome to Pillsbury SALT, Zack!
Pillsbury SALT is pleased to welcome Zachary Atkins to the team! Zack previously served as a deputy general counsel to Fitzgerald USA handling a diverse range of projects from tax to corporate matters. Prior to joining Fitzgerald, his practice focused primarily on state and local tax issues as an associate…