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!
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SeeSALT Blog
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Try, Try Again—NY’s Convenience of the Employer Rule Sources Nonresident Wages to NY Even During the Pandemic
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…
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California Credit Claim Denials: California OTA Issues Two Opinions Rejecting Taxpayers’ Submitted Evidence to Substantiate Claimed California R&D Tax Credits
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…
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Congratulations, Zack and Evan!
The SALT team would like to extend our congratulations to Zachary Atkins and Evan Hamme on their promotions to Partner!
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California Trial Court Grants Industry Trade Association’s Motion for Summary Adjudication, Declaring Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid
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…
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Maine Expressly Requires Express Scripts to Apportion Services Receipts Using a Look-Through Approach
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…
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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…