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California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms

Following the IRS’s announcement of tax relief for 41 California counties* affected by severe winter storms, the California Franchise Tax Board (FTB) and California Department of Tax and Fee Administration (CDTFA) announced similar relief for state-level taxes and fees. The FTB automatically extended the filing and payment deadlines for businesses…

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Maryland Digital Ad Tax Updates: Comptroller Seeks Stay of State Court Decision Striking Tax and Recently Dismissed Federal Challenge is Under Appeal

The saga continues over Maryland’s Digital Advertising Gross Revenues Tax (Digital Ad Tax), much to the chagrin of Peter Franchot, Comptroller of Maryland, who is tasked with administering and enforcing the tax and has publicly issued concerns with the constitutionality of the tax. On October 20, 2022, Maryland’s Circuit Court…

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Second Place Is Just the First Place Loser: Ohio Supreme Court Rejects State’s Sourcing of NASCAR Intangible Receipts to Ohio

In a much-anticipated decision concerning the situsing of receipts from intangibles for Ohio commercial activity tax (CAT) purposes, the Ohio Supreme Court rejected the Ohio Department of Taxation’s attempt to situs NASCAR Holdings, Inc.’s broadcast revenue, media revenue, licensing fees, and sponsorship fees to Ohio.  The court’s opinion in NASCAR Holdings,…

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Texas Court of Appeals Confirms Cost-of-Performance Method Is Proper to Source Service Receipts

The Texas Court of Appeals agreed with Sirius XM Radio Inc.’s (Sirius XM) cost-of-performance (COP) method to determine the fair value of Sirius XM’s services performed in Texas. Earlier in this litigation, the Texas Supreme Court found in favor of Sirius XM that origination sourcing, i.e., to where services are…

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2022 California Alliance of Taxpayer Advocates Annual Conference

Pillsbury SALT partners Breann Robowski and Craig Becker will be presenting at the 2022 California Alliance of Taxpayer Advocates Annual Conference, December 7-9, 2022. Breann and Craig are presenting on the topic “California Property Tax – Legal Update” at the conference on December 8. For more information and to register,…

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Pillsbury SALT’s Carley Roberts Featured by California Lawyer’s Association’s “Toast to Women in Tax: Inspiring Leadership”

Pillsbury SALT’s Carley Roberts has been featured by California Lawyer’s Association’s “Toast to Women in Tax: Inspiring Leadership” at the 2022 Tax Annual Meeting. This year’s Toast to Women in Tax honored women who have achieved professional success, exemplify what it means to be a leader and helped shape the…

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Three Strikes, You’re Out! New York Has Another Miss in Sales Tax Case Against a Service Provider Under the “Primary Function” Test

An administrative law judge (ALJ) in the New York State Division of Tax Appeals cancelled the New York State Division of Taxation’s notice of determination asserting sales tax on petitioner’s verification services. The October 6, 2022 determination in Matter of Employment Screening Services, LLC, confirms that petitioner’s services are properly…