SeeSALT BlogSALT attorneys Zachary Atkins, Evan Hamme and Aruna Chittiappa will each be speaking at COST’s State Indirect Tax Seminar on December 13, 2023 in Atlanta, GA.
Articles Posted in Issues
60th Annual TEI New York Chapter Tax Symposium
Posted
Zachary Atkins will be speaking at the 60th Annual TEI New York Chapter Tax Symposium on December 6.
No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01
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In the Appeal of Southern Minnesota Beet Sugar Cooperative (2023-OTA-342P) (Beet Sugar), the California Office of Tax Appeals (OTA) issued a precedential opinion holding the California Franchise Tax Board (FTB) is not entitled to apply its FTB Legal Ruling 2006-01 (Apr. 28, 2006) to prohibit taxpayers from including in their apportionment factors property, payroll, and sales that generated statutorily deductible income. The OTA’s guidance on the FTB’s interpretation and application of Legal Ruling 2006-01 in this opinion also has implications beyond the specific issue in Beet Sugar, as the FTB has been attempting to expand the application of the limited legal ruling to other inapplicable situations. For example, an opinion by the OTA in the Appeal of Microsoft Corporation & Subsidiaries (OTA Case Number 21037336) is also anticipated to be issued soon, which appeal concerns whether the FTB is entitled to apply Legal Ruling 2006-01 to prohibit taxpayers from including in their apportionment sales factors statutorily deductible foreign dividend amounts.
Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business
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On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT)[1] including expanding the definition of what constitutes a “unitary business.” The expanded definition now includes affiliated entities that may not have previously met the requirements for combined group membership for CBT purposes. 
California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid
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A California trial court denied summary judgment in the American Catalog Mailers Association’s (ACMA) action that seeks to invalidate Franchise Tax Board (FTB) guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes. However, the court signaled it may invalidate the FTB’s guidance on the basis it constitutes underground regulations and violates California’s Administrative Procedure Act. Continue Reading ›
COST’s 54th Annual Meeting
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Pillsbury attorneys Carley Roberts, Zachary Atkins, and Evan Hamme will present at COST’s 54th Annual Meeting in Las Vegas, NV.
Pillsbury SALT Recognized in Best Lawyers, 2024 edition
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Congratulations to our Pillsbury SALT team for earning recognition in the 2024 edition of Best Lawyers in America and Best Lawyers: Ones to Watch. 
Partner Jeffrey Vesely was recognized as a Lawyer of the Year in San Francisco for Litigation and Controversy – Tax.
Congratulations to all recognized!
Best Lawyers
Jeffrey Vesely (Lawyer of the Year)
Craig Becker
Carley Roberts
Ones to Watch
Christopher Koester
New Jersey Enacts Significant Changes to Corporation Business Tax Law
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On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey’s Corporation Business Tax (CBT). The bill enacted a variety of clarifications, corrections and modifications to the CBT.
Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection
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The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales terms obtained from Minnesota customers by the company’s salespeople.
2023 Wichita Property Tax Conference
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Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25.
