Close

SeeSALT Blog

Updated:

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…

Updated:

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…

Updated:

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)…

Updated:

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…

Updated:

“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…

Updated:

Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based Sourcing

On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes.  In Billmatrix Corp. v. State of Florida, Department of Revenue, No. 2020-CA-000435 (Fla. 2d Cir. Ct. Mar. 1, 2023), the court…

Updated:

2023 COST Intermediate/Advanced State Income Tax School

Pillsbury SALT attorney Evan Hamme will be presenting at the 2023 COST Intermediate/Advanced State Income Tax School on May 8 in DFW Airport, Texas. Evan, along with Trevor Mauck (Baker & McKenzie), will be presenting on the topic “Filing Methodologies.” This session will cover the various income tax filing methodologies…

Updated:

COST/CTC Mid-West Regional State Tax Seminar

Pillsbury SALT attorneys Carley Roberts, Craig Becker, Zachary Atkins and Kristen Sharp will be presenting at the upcoming COST/CTC Mid-West Regional State Tax Seminar on Wednesday, May 3 in Rolling Meadows, Illinois. Pillsbury and BDO will be sponsoring the seminar which will present updates on significant state tax issues with…