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…
SeeSALT Blog
TEI’s 2023 Annual Conference
Please join Pillsbury partner Jeff Vesely at TEI’s 2023 Annual Conference – a 75th Anniversary Celebration in New York City. Jeff will be participating on a panel titled, “State Tax Policy: As Deficits Return Will the Tide Change?” This conference will take place October 22 – 25 at the New…
COST’s 54th Annual Meeting
Pillsbury attorneys Carley Roberts, Zachary Atkins, and Evan Hamme will present at COST’s 54th Annual Meeting in Las Vegas, NV. Zack is partnering with Dorothy Lo (PwC), Nathan Runyan (Holland & Hart LLP), and Chris Wilson (Holland & Knight LLP) on October 18 to present on the topic, “The Sales Taxation…
Pillsbury SALT Recognized in Best Lawyers, 2024 edition
Congratulations to our Pillsbury SALT team for earning recognition in the 2024 edition of Best Lawyers in America and Best Lawyers: Ones to Watch. Partner Jeffrey Vesely was recognized as a Lawyer of the Year in San Francisco for Litigation and Controversy – Tax. Congratulations to all recognized! Best…
Taxation Without Representation: Michigan Supreme Court Says Neither State Law Nor the U.S. Constitution Requires Inclusion of Receipts From Deemed Asset Sale in Sales Factor
In a split decision, the Michigan Supreme Court rejected a taxpayer’s assertion that applying the standard apportionment formula to gain derived from a deemed asset sale led to a grossly distorted, unconstitutional result. The court held in Vectren Infrastructure Services Corporation v. Department of Treasury, No. 163742 (July 31, 2023),…
30th Annual Paul J. Hartman SALT Forum
Join Carley Roberts and Evan Hamme during this upcoming SALT event. During the Forum, Carley will be part of a panel discussion on the application of the true object test and similar tests. Evan will appear on a panel looking at intercompany transactions and transfer pricing. What Exactly Did I…
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…
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
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…
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,…