SeeSALT BlogSALT partners Aruna Chittiappa and Evan Hamme will be speaking at COST’s Spring Conference taking place April 20-23, 2026 in Coral Gables, FL.
2026 COST Spring Conference
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Articles Posted in Issues
California Groups File Signatures for Initiative to Curtail Local Taxes
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A coalition of business and antitax groups announced that it has submitted more than 1.3 million signatures to qualify the “Local Taxpayer Protection Act to Save Proposition 13” for the November 2026 ballot. These groups include the Howard Jarvis Taxpayers Association, the California Business Roundtable, the California Taxpayers Association, and the California Business Properties Association.
Not the CAT’s Meow: Ohio Supreme Court Reins in the Continuous Delivery Theory for Situsing Receipts
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Recent Ohio Supreme Court decisions addressing the situsing of receipts under the Commercial Activity Tax (CAT) underscore both the limits of the “continuous delivery theory” and the evidentiary hurdles taxpayers face when seeking refunds for transactions involving Ohio distribution centers.
Read together, VVF Intervest, L.L.C. v. Harris, Slip Op. No. 2025-Ohio-5680 (Ohio Dec. 24, 2025), and Jones Apparel Group/Nine West Holdings v. Harris, Slip Op. No. 2026-Ohio-74 (Ohio Jan. 14, 2026), confirm a transaction-focused approach to CAT situsing while highlighting the evidentiary showing required to substantiate refund claims.
2026 ABA-IPT Advanced State Income Tax Seminar
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Pillsbury SALT partner Carley Roberts will be presenting at the 2026 ABA-IPT Advanced State Income Tax Seminar on March 17.
CalTax 100th Annual Meeting
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SALT partners Craig Becker and Robert P. Merten III will be presenting at this year’s CalTax Annual Meeting.
No Contract, No Look-Through: Wisconsin Draws a Line on Software Receipts Sourcing
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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.
2025 TEI Annual Conference
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Pillsbury SALT associate Breanna Zagorski will be presenting at the 2025 TEI Annual Conference on Oct. 28, 2025.
32nd Annual Paul J. Hartman State & Local Tax Forum
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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.
Sourced and Settled: California FTB Finalizes its Long-Awaited Market-Sourcing Regulation, Applicable to Tax Year 2026 and Beyond
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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:
COST 56th Annual Meeting
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Join Pillsbury SALT partners Zachary Atkins and Evan Hamme for their presentations at COST’s 56th Annual Meeting.
