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…
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…
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…
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…
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…
Pillsbury SALT attorneys Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present during TEI’s New York Chapter SALT Meeting on April 19 taking place at Pillsbury’s New York Office. Pillsbury SALT is pleased to share three presentations at the April meeting: SALT Cases Impacting…
California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (ACA 11) which proposes to abolish the State Board of Equalization (BOE) and reassign its responsibilities to other state tax agencies effective January 1, 2026. The BOE is a constitutionally established elected body that has served the people of California for…
For years, some California counties have been imposing disproportionately higher property tax rates on centrally assessed property despite the state constitutional mandate that this property be assessed like locally assessed property. In a challenge brought by centrally assessed utilities, the California Court of Appeal conceded that the higher property tax…
In addition to the tax relief announced in January, the California Franchise Tax Board (FTB) has automatically extended the income tax filing and payment deadlines for businesses and individuals affected by severe winter storms in California until October 16, 2023. The tax relief now applies to businesses and residents…
Pillsbury SALT partner Carley Roberts will be presenting at California Taxpayers Association’s 97th Annual Meeting on March 23. Carley will be participating in a panel discussion on the topic “Taxation of the Digital World.” The panel will delve into the implications of an increasingly digital world and how state and…