SeeSALT Blog
Pillsbury SALT partner Annie Huang will present during COST’s 51st Annual Meeting on October 22. 
Partnering with Robert Johnson (Crowe), Eran Liron (PwC) and Ruben Sislyan (Greenberg Traurig), Annie will present “Market Sourcing through Alternative Apportionment or Creative Characterizations of Activity,” moderated by Stephanie Do (COST). Few issues have created greater angst or spawned more litigation than state efforts to impose market sourcing of services on out-of-state taxpayers. As the service sector has grown, so has single-sales factor apportionment, which often makes market sourcing an all-or-nothing proposition to both states and taxpayers. Although many states have modified UDITPA to move from COP to market sourcing, many have not and are using tools such as Sec. 482, forced combination, and creative characterizations of benefits received. And states that changed are trying to stanch the revenue outflow from in-state service companies as well. This session will provide an overview and discussion of some of the more bizarre and inconsistent approaches taken by states on this issue.
COST’s 51st Annual Meeting offers sessions of interest to every state tax professional in industry, whether a COST member or otherwise, as well as in the consulting, accounting and legal profession. The program covers all types of state and local taxes that business taxpayers are confronted with today and provides updates on key SALT issues.
For more information and to register, please click here.
Pillsbury SALT was proud to present TEI/IPT Silicon Valley’s State and Local Tax Day & IPT Joint Meeting on December 5! The team presented a 3/4-day seminar that focused on topics related to the State and Local Tax implications of the Tax Cuts and Jobs Act, the U.S. Supreme Court’s decision in Wayfair, and other hot topics in state and local taxation.
The Multistate Tax Commission (MTC) is updating its Public Law 86-272 guidance, “Statement of Information Concerning Practices of Multistate Tax Commission and Signatory States under Public Law 86-272,” to address internet activities. This guidance was last updated in 2001. The latest draft guidance, dated October 15, 2019, provides examples of when the use of an “interactive” website will defeat P.L. 86-272 immunity, even if the company has no other contact with the customer’s state. Such examples include: