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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.image-removebg-preview-5-298x300 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.

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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.

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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:Capture-2-300x101

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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.CDTFA-Logo-Horizontal-Full-2-300x91

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.

Read more on Pillsbury Law’s website.

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Pillsbury SALT is excited to welcome back Annie H. Huang to the team!

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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.