SeeSALT BlogSALT partner Zachary Atkins will be presenting at the 2026 Wall Street Tax Association Spring Tax Conference.
Articles Posted in Sales and Use Tax
No Contract, No Look-Through: Wisconsin Draws a Line on Software Receipts Sourcing
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In a recent decision, the Wisconsin Tax Appeals Commission drew a bright line for sourcing receipts from software for sales factor apportionment purposes: without a contract with the end-user, a company cannot source receipts from software to the end-user’s location. Instead, the receipts must be sourced based on the location of the company’s immediate customer, even if most end-users are elsewhere.
Welcome back to Pillsbury SALT, Annie!
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Pillsbury SALT is excited to welcome back Annie H. Huang to the team!
Annie’s experience focuses on state and local tax matters, including corporate franchise and income, personal income, sales and use, and gross receipts and other local taxes.
Annie brings not only strong legal experience but also a genuine enthusiasm for building relationships and supporting clients through complex challenges.
She joins Pillsbury’s San Francisco office as a partner. Read more here.
Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals
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The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the issuing agency, but its authority extends to setting aside the regulation for that appeal. OTA lacks authority to invalidate or repeal the regulation more broadly or to apply its conclusions outside the specific appeal.
California Imposes Further Disclosure Requirements for Local Sales Tax Sharing Agreements
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On September 28, 2024, California enacted Assembly Bill 2854, which imposes new disclosure requirements on local agencies (i.e., chartered or general law cities and counties) that have entered into local sales tax sharing agreements with retailers. Generally, pursuant to a local sales tax sharing agreement, a retailer will agree to establish a new sales or fulfillment center in a local jurisdiction and source its sales to that local jurisdiction. In exchange, the local jurisdiction will provide the retailer a rebate on the local sales tax revenue generated for the local jurisdiction.
31st Annual Paul J. Hartman SALT Forum
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Pillsbury SALT partner Zachary Atkins will present at the 31st Annual Paul J. Hartman SALT Forum on October 28.
Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes
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The California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA) and California Employment Development Department (EDD) announced tax relief for certain California counties affected by severe winter storms.
2024 ABA-IPT Advanced Sales and Use Tax Seminar
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SALT partner Carley Roberts will moderate a panel at this year’s ABA-IPT Advanced Sales and Use Tax Seminar.
COST State Indirect Tax Seminar
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SALT 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.
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