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New Jersey Enacts Significant Changes to Corporation Business Tax Law

On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey’s Corporation Business Tax (CBT). The bill enacted a variety of clarifications, corrections and modifications to the CBT. The bill includes substantive amendments to CBT provisions, such as: Economic Nexus Threshold: The bill…

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Pillsbury SALT Attorney Zachary Atkins Comments on Look-Through Sourcing Methods and Litigation

Pillsbury SALT attorney Zachary Atkins was quoted in the Law360 article “Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say” from his presentation during the Southeastern Association of Tax Administrators 2023 Annual Conference on July 18. Read more: Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say – Law360 Tax Authority

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Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection

The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales terms obtained from Minnesota customers by the company’s salespeople. PL 86-272 is a federal law enacted in 1959 that…

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2023 Wichita Property Tax Conference

Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25. Breann will be partnering with David Crapo (Crapo Deeds) for a “Legal Update – Legislative Lightning Round” session at the Wichita Property Tax Conference that provides valuation and assessment topics for complex industries,…

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2023 SEATA Annual Conference

Pillsbury SALT attorney Zachary Atkins will be presenting at the Southeastern Association of Tax Administrators 2023 Annual Conference on July 18 in Little Rock, Arkansas. Zack is partnering with Breen Schiller (EY) to present on the topic “Recent Trends in Receipts Factor Sourcing.” This three-day program is packed with keynote…

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A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain “Qualified Tangible Personal Property”

Pillsbury SALT attorneys Zachary Atkins, Craig Becker, Carley Roberts, & Richard Nielsen discuss California Assembly Bill 52.  AB 52 would provide corporation and personal income tax credits for local sales and use and district taxes paid on machinery and equipment primarily used in manufacturing, research and development, electric power generation…

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New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts from ADSL and Fiber Broadband Sales

  An administrative law judge with the New York State Division of Tax Appeals held that the federal Internet Tax Freedom Act (ITFA) preempted the imposition of New York franchise tax and a metropolitan transportation business tax (MTA) surcharge on gross receipts from sales of asymmetric digital subscriber line (ADSL)…

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No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit

The California Office of Tax Appeals (OTA) held a California resident was not entitled to claim an other state tax credit (OSTC) for taxes paid to Massachusetts because gain from the sale of an LLC membership interest was wholly sourced to the taxpayer’s domicile under California law. The taxpayer contended…

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“If You Don’t Make It There, You Can’t Make It Anywhere:” New York’s Zero Manufacturing Rate Requires New York Property

Our state and local tax team comments on the New York State Division of Tax Appeals (DTA) administrative law judge (ALJ) determination that Raytheon Company and affiliates (Raytheon) did not qualify for New York’s zero percent tax rate for manufacturers or the reduced tax rate for qualified emerging technology companies…