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),…
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…
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 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
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…
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,…
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…
Congratulations to our Pillsbury SALT team, again earning recognition in the Chambers USA ranking guide. Our California SALT team earned a Band 1 ranking for the 3rd year, with partners Jeffrey Vesely (Band 1) earning his 17th ranking, Carley Roberts (Band 1) with her 15th ranking, and Robert Merten (Band…
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…
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)…