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…
The SALT team would like to extend our congratulations to Zachary Atkins and Evan Hamme on their promotions to Partner!
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…
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…
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…
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…
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…
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…
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…
The Pillsbury SALT team had a memorable time last week at COST’s 54th Annual Meeting in Las Vegas, NV. Carley Roberts, Zachary Atkins and Evan Hamme were all speakers during the annual meeting, and the rest of the team attended a variety of substantive sessions on SALT issues and state…