Pillsbury is proud to partner with TEI’s NY Chapter to host their State & Local Chapter Meeting. Join Pillsbury SALT and TEI NY Chapter members for “Sales Tax: Transformation in Action.” In a presentation designed for sales tax compliance professionals at all levels, Sheila Rao, Senior Vice President, TEI NY…
Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not qualify for the state’s dividends received deduction. Nebraska Dep’t of Revenue, Gen. Info. Letter 24-19-1…
On Sept. 30-Oct. 2, members of Pillsbury SALT will lead discussions at COST’s property tax workshop in Las Vegas. This event aims to bring multistate property tax professionals together and discuss timely legislative and litigation updates, trends and opportunities to make sure your business’s property is not over taxed. Topics…
The California Office of Tax Appeals (OTA)—in a 3-0 pending precedential opinion granting the Appeal of Jali, LLC—has rejected the Franchise Tax Board’s (FTB) 0.2 percent ownership threshold as the new bright-line standard for determining whether an out-of-state LLC member is actively “doing business” (and thereby required to file and…
The Fifth Appellate District of the California Court of Appeal has struck another blow to taxpayers claiming California unconstitutionally discriminates against interstate commerce by permitting intrastate unitary businesses to file using either a combined reporting method or separate accounting method, while requiring interstate unitary businesses to file under the combined…
(This article originally was published by Law360 on August 21, 2019.) The repercussions of the California Supreme Court’s August 2017 opinion in California Cannabis Coalition, et al. v. City of Upland, et al.1 continue to reverberate, leading San Francisco’s business taxpayers to wonder what practical precautions to consider. In a February article, we analyzed…
The New York State Tax Appeals Tribunal (TAT) issued a decision that addresses sourcing “services” vs. the catch-all “other business receipts” for years prior to New York Tax Reform (tax years beginning prior to 1/1/2015). The TAT found that the taxpayer, who provided electronic litigation support to its clients, was…
After a successful SALT Retreat in Napa, Calif., the team headed to Foster City to present on topics at the COST State and Local Tax Workshop for Technology Companies. Carley Roberts, Craig Becker and Jeffrey Vesely spoke on a variety of topics including an overview of new and established local taxes…
At the 2019 Inaugural Pillsbury SALT Retreat in Napa, Calif., the team spent the weekend learning more about each other, strategizing ways to better serve our clients, and attending a variety of substantive sessions. We kicked off the retreat with various “ice breaker” activities, opening the dialogue for even more…
(This article originally was published by Law360 on July 22, 2019.) On July 5, the San Francisco Superior Court issued a pair of rulings in favor of the city and county of San Francisco, finding that two local special taxes introduced by voter initiatives were valid even though they passed…