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Welcome to Pillsbury SALT, Breanna!

Pillsbury SALT is excited to welcome Breanna Zagorski to the team! Breanna’s experience includes a variety of state and local tax matters, including multistate litigation, planning, audit defense and controversy issues. She joins Pillsbury’s New York office as an associate. 5 Questions with Breanna:  1. What drew you to the…

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Texas Comptroller Takes a Serious Look at Sourcing Regulation After SiriusXM Loss

The Texas Comptroller of Public Accounts has proposed significant amendments to its service receipts sourcing regulation in the wake of the Texas Supreme Court’s decision in Sirius XM Radio, Inc. v. Hegar, 643 S.W.3d 402 (Tex. 2022).  The proposed amendments would dispense with the Comptroller’s long-standing “receipts-producing, end-product act” test…

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Recent Measures Establish Unprecedented Tax Increases on Real Property in California Cities

Our state and local tax team collaborated with our real estate colleagues to summarize the effects of Measure ULA (Los Angeles), Measure GS (Santa Monica), Measure M (San Francisco) and Measure K (Palo Alto). Read More: Recent Measures Establish Tax Increases on Real Property in CA Cities (pillsburylaw.com)

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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,…