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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…

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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…

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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…

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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  In its unpublished April 11, 2024, opinion, the…

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COST’s 2024 SALT Workshop for Technology Companies

Pillsbury SALT attorneys Carley Roberts, Jeffrey Vesely, Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present at this year’s SALT Workshop for Technology Companies on August 14 and 15. Zachary Atkins: Escalating Burden of Gross Receipts Taxes and Local Taxes (Including Recent SF Activity)…