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COST State Indirect Tax Seminar

SALT attorneys Zachary Atkins, Evan Hamme and Aruna Chittiappa will each be speaking at COST’s State Indirect Tax Seminar on December 13, 2023 in Atlanta, GA. This event will present an update on significant state indirect tax issues with a focus on sales/use tax, plus unclaimed property and property tax…

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60th Annual TEI New York Chapter Tax Symposium

Zachary Atkins will be speaking at the 60th Annual TEI New York Chapter Tax Symposium on December 6. Zack is partnering with Stephen Kranz (McDermott Will & Emery LLP) to speak on the topic, “State and Local Non-Income Taxes – What You Need to Know, Including Franchise Taxes, Gross Receipts…

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No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01

  In the Appeal of Southern Minnesota Beet Sugar Cooperative (2023-OTA-342P) (Beet Sugar), the California Office of Tax Appeals (OTA) issued a precedential opinion holding the California Franchise Tax Board (FTB) is not entitled to apply its FTB Legal Ruling 2006-01 (Apr. 28, 2006) to prohibit taxpayers from including in…

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Congratulations Carley Roberts! Recipient of the 2023 Benjamin F. Miller Award

The entire Pillsbury State and Local Tax (SALT) Team is very proud to congratulate our practice leader Carley Roberts for receiving the prestigious Benjamin F. Miller award during this year’s California Annual Meeting of the Tax Bar and Tax Policy Conference. This award is presented annually by the California Lawyers…

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Pillsbury SALT Attorneys Zack Atkins and Evan Hamme Serve as Panelists at Paul J. Hartman State & Local Tax Forum

State & Local Tax special counsel Zack Atkins and counsel Evan Hamme recently served on panels discussing important developments in state and local tax at the Paul J. Hartman State and Local Tax Forum in Nashville, Tennessee. Read more about their panels on Tax Notes (subscription required): Panelists Discuss Challenges…

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Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business

On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT)[1] including expanding the definition of what constitutes a “unitary business.”  The expanded definition now includes affiliated entities that may not have previously met the requirements for combined group…

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California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid

A California trial court denied summary judgment in the American Catalog Mailers Association’s (ACMA) action that seeks to invalidate Franchise Tax Board (FTB) guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes.  However, the court signaled it may invalidate the FTB’s…