In a recent decision, the Wisconsin Tax Appeals Commission drew a bright line for sourcing receipts from software for sales factor apportionment purposes: without a contract with the end-user, a company cannot source receipts from software to the end-user’s location. 
Instead, the receipts must be sourced based on the location of the company’s immediate customer, even if most end-users are elsewhere.
Pillsbury SALT associate Breanna Zagorski will be presenting at the 2025 TEI Annual Conference on Oct. 28, 2025.
Pillsbury SALT partners Carley Roberts, Zachary Atkins and Aruna Chittiappa will be presenting at the 32nd Annual State and Local Tax Forum taking place Oct. 27–29, 2025.
After nearly a decade in development, the California Franchise Tax Board (FTB) has finalized its amended market-based sourcing regulation under Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.
The regulation was approved by the Office of Administrative Law and filed with the Secretary of State on August 27, 2025. The revised rules will apply to tax years beginning on or after January 1, 2026. Among the most significant changes to the regulation are:
Join Pillsbury SALT partners Zachary Atkins and Evan Hamme for their presentations at COST’s 56th Annual Meeting.
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.
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.
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.
Pillsbury SALT partner Aruna Chittiappa will be speaking at NYU’s Introduction to State and Local Tax program.
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