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.
Articles Posted in Issues
2023 Wichita Property Tax Conference
Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25.
A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain “Qualified Tangible Personal Property”
Pillsbury SALT attorneys Zachary Atkins, Craig Becker, Carley Roberts, & Richard Nielsen discuss California Assembly Bill 52. AB 52 would provide corporation and personal income tax credits for local sales and use and district taxes paid on machinery and equipment primarily used in manufacturing, research and development, electric power generation or production, or electric power storage and distribution.
New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts from ADSL and Fiber Broadband Sales
An administrative law judge with the New York State Division of Tax Appeals held that the federal Internet Tax Freedom Act (ITFA) preempted the imposition of New York franchise tax and a metropolitan transportation business tax (MTA) surcharge on gross receipts from sales of asymmetric digital subscriber line (ADSL) and fiber broadband aggregation and access services (Fiber Broadband).
No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit
The California Office of Tax Appeals (OTA) held a California resident was not entitled to claim an other state tax credit (OSTC) for taxes paid to Massachusetts because gain from the sale of an LLC membership interest was wholly sourced to the taxpayer’s domicile under California law. Continue Reading ›
Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based Sourcing
On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes. In Billmatrix Corp. v. State of Florida, Department of Revenue, No. 2020-CA-000435 (Fla. 2d Cir. Ct. Mar. 1, 2023), the court strongly rebuked the Florida Department of Revenue for attempting to apply market-based sourcing in contravention of its own COP sourcing regulation. Continue Reading ›
2023 COST Intermediate/Advanced State Income Tax School
Pillsbury SALT attorney Evan Hamme will be presenting at the 2023 COST Intermediate/Advanced State Income Tax School on May 8 in DFW Airport, Texas.
COST/CTC Mid-West Regional State Tax Seminar
Pillsbury SALT attorneys Carley Roberts, Craig Becker, Zachary Atkins and Kristen Sharp will be presenting at the upcoming COST/CTC Mid-West Regional State Tax Seminar on Wednesday, May 3 in Rolling Meadows, Illinois.
TEI New York Chapter SALT Meeting
Pillsbury SALT attorneys Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present during TEI’s New York Chapter SALT Meeting on April 19 taking place at Pillsbury’s New York Office.
Property Tax Rate Dispute Merits California Supreme Court Review
For years, some California counties have been imposing disproportionately higher property tax rates on centrally assessed property despite the state constitutional mandate that this property be assessed like locally assessed property.
In a challenge brought by centrally assessed utilities, the California Court of Appeal conceded that the higher property tax rates disproportionally burden utility company property but concluded that this disparity does not violate the California Constitution.
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