SeeSALT BlogJoin Pillsbury SALT partners Zachary Atkins and Evan Hamme for their presentations at COST’s 56th Annual Meeting.
COST 56th Annual Meeting
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Articles Posted in Issues
California Updates Tax Regulations on Technology Transfer Agreements
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In a move to untangle the complexities surrounding sales and use tax in technology transfer arrangements, California’s tax regulator has laid out three major proposals.
SALT attorneys Jeff Vesely and Richard Nielsen dissect these changes—from adding clarification to introducing rebuttable presumptions—that could dial down uncertainty at the crossroads of sales/use tax and tech licensing agreements.
Welcome back to Pillsbury SALT, Annie!
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Pillsbury SALT is excited to welcome back Annie H. Huang to the team!
Annie’s experience focuses on state and local tax matters, including corporate franchise and income, personal income, sales and use, and gross receipts and other local taxes.
Annie brings not only strong legal experience but also a genuine enthusiasm for building relationships and supporting clients through complex challenges.
She joins Pillsbury’s San Francisco office as a partner. Read more here.
Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals
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The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the issuing agency, but its authority extends to setting aside the regulation for that appeal. OTA lacks authority to invalidate or repeal the regulation more broadly or to apply its conclusions outside the specific appeal.
NYU Introduction to State and Local Tax
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Pillsbury SALT partner Aruna Chittiappa will be speaking at NYU’s Introduction to State and Local Tax program.
2025 Summer Tax Institute
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Pillsbury SALT partner Robert P. Merten III will be an instructor for the 2025 Summer Tax Institute, hosted by the UC Davis School of Law.
California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)
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Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January 1, 2025, and would align California tax law with numerous federal provisions enacted over the past decade. Notable provisions include:
COST 2025 Spring Conference
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SALT partners Aruna Chittiappa and Evan Hamme will be presenting at COST’s 2025 Spring Conference taking place April 28 – May 1, 2025.
Technology Transfer Agreements: An Update on Latest Developments in California
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The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs).
On January 22, 2025, the CTIA (formerly the Cellular Telecommunications and Internet Association) submitted comments. The California Taxpayers Association (CalTax) and the Silicon Valley Leadership Group (SVLG) also submitted their comments in a joint letter.
