SeeSALT BlogPillsbury SALT attorneys Carley Roberts, Zachary Atkins, Robert Merten III, Aruna Chittiappa and Jeff Phang will present during the TEI Chicago Virtual State Income Tax Program on December 9.
Articles Posted in Income Tax
Taxpayer Files Court Action Challenging California’s Proposition 39 (2012) and its Mandatory Single-Sales Factor Apportionment Formula
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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.”
Telework Nexus Burdens Grow As States Shed Pandemic Relief
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Pillsbury Counsel Evan Hamme discussed how the rise in remote work could lead to tax compliance issues for employers with Law360. Read more here.
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California Lawyers Association’s 2021 Annual Income Tax Seminar
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Pillsbury SALT attorneys Robert Merten and Lexi Louderback will present during CLA’s Annual Income Tax Seminar on July 15.
Delaware Court Invalidates Division’s NOL Limitation Policy
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Pillsbury State & Local Tax 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.
Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on “Convenience of the Employer” Rule
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The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take credits
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 ›
TEI’s Wisconsin Chapter Meeting
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Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18.
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How to Be Reasonable When Reasonably Approximating the Market: Part I
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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.
Read more here. Continue Reading ›
Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity
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A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions 
for 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 attorney Zack Atkins explains.
To read the full article, please click here.
California Legislature Passes Governor Newsom’s Proposal to Suspend California Net Operating Loss Deductions and Limit Tax Credits during 2020 – 2022
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SeeSALT partners Jeff Vesely, Craig Becker, Carley Roberts and Breann Robowski break down Governor Newsom’s proposed tax legislation, recently passed by the California Legislature, to raise additional income tax revenue to assist in balancing the California budget. (AB 85). The Senate and Assembly each achieved the two-thirds majority vote required for California tax increases (27-11 in the Senate and 56-20 in the Assembly), with Governor Newsom expected to sign the legislation later this week.
To view the full article, please click here.