An administrative law judge in the New York State Division of Tax Appeals rejected the state’s position that a taxpayer providing a web-based service which allowed clients to identify effective and ineffective messaging through information, analysis, and reports was selling taxable software. Following the rationale applied in a series…
In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by prematurely using reasonable approximation to source the income of a multistate unitary business. During the tax year…
A Maryland state court struck down the state’s Digital Advertising Gross Revenues Tax (“Digital Ad Tax”) as invalid under both the federal Internet Tax Freedom Act (“ITFA”) and U.S. Constitution. Enacted February 12, 2021, Maryland’s Digital Ad Tax by its terms applies to any person with at least $1 million…
A New Mexico Hearing Officer found that Gross Receipts Tax does not apply to a taxpayer’s markup for services performed outside New Mexico, but the taxpayer’s reimbursements for payroll to New Mexico employees are taxable New Mexico receipts. In Protest of Talbridge, the taxpayer was a Texas employment agency with…
The SALT team briefs the outcomes of the first meeting of the Multistate Tax Commission (MTC). Read More: Model Receipts Sourcing Regulations Work Group’s Curious First Meeting(pillsburylaw.com)
Pillsbury SALT partner Carley Roberts will be presenting at the upcoming National Association of State Bar Tax Sections (NASBTS) Annual Conference. Carley will be partnering with Marilyn Wethekam (HMB Legal Counsel) to present on the topic, “Let the Countdown Begin! 2022’s Noteworthy SALT Cases.” The panelists will discuss case developments,…
Pillsbury SALT partner Carley Roberts will be presenting at the Annual Meeting of the California Tax Bar and California Tax Policy Conference on November 3. The Annual Meeting of the California Tax Bar and California Tax Policy Conference will be taking place in San Diego and features an agenda of…
The American Catalog Mailers Association (ACMA), which describes itself as the nation’s leading industry trade association advocating for catalog, online, direct mail, and other remote-selling merchants and their suppliers, has filed suit against the California Franchise Tax Board (FTB) in the San Francisco County Superior Court of California. ACMA’s complaint…
Pillsbury SALT partner Robert P. Merten III and counsel Evan Hamme will present at COST’s 53rd Annual Meeting in Orlando, Florida. Evan will be partnering with Peter Larsen (Akerman LLP) on October 25 to present on the topic, “How to do SALT in 2022 and Beyond.” This session will explore…
Pillsbury SALT partner Carley Roberts will be presenting at TEI’s Annual Conference on October 25. Carley will present on the topic, “SALT Considerations During an Economic Slowdown.” TEI’s Annual Conference, being held October 23-26, 2022 at the Westin Kierland Resort & Spa in Scottsdale, Arizona, will deliver a wealth of…