Articles Posted in Income Tax


In One Technologies LLC v. Franchise Tax Board, an out-of-state California corporate taxpayer filed suit in California trial court challenging the state’s mandatory single sales factor apportionment formula on the basis its passage in 2012 via voter initiative Proposition 39 unconstitutionally violated the “single subject rule.”

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Pillsbury State & Local Tax partner Marc Simonetti, special counsel Zachary Atkins explores the recent Delaware court decision of Verisign and the implications it has for taxpayers in Tax Notes State’s SeeSALT Digest.

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The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take creditsct-150x150 for tax paid to other states while working from Connecticut during the pandemic.  Connecticut law currently allows credits for tax paid to another state only if: (1) the individual was physically located in such other state while working; or (2) the individual is a resident of a state that applies the “convenience of the employer” sourcing rule.  Two bills have been introduced, both of which would expand the allowable credits only for Connecticut residents and part-year residents for the tax year beginning January 1, 2020.  H.B. 6183; S.B. 873. Continue Reading ›


Partner Carley Roberts and counsel Robert Merten III authored Part 1 of a multi-part series in Tax Notes State’s SeeSALT Digest to review the landscape of market-based sourcing rules and provide an in-depth focus on various states’ use of reasonable approximation.


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A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions Verisign-DE-300x180for members of federal consolidated groups, holding that the policy violated the Uniformity Clause of the state constitution. Verisign, Inc. v. Director of Revenue, No. N19C-08-093 JRJ (Del. Super. Ct. Dec. 17, 2020). The decision presents a potential refund opportunity for Delaware corporate taxpayers who were members of a federal consolidated group, and for Delaware corporate income tax purposes had their separate-company NOL deductions limited to the group’s consolidated NOL.

Pillsbury attorneys Marc Simonetti and Zack Atkins explain.

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