Pillsbury SALT attorney Zachary Atkins was quoted in the Law360 article “Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say” from his presentation during the Southeastern Association of Tax Administrators 2023 Annual Conference on July 18.
Read more: Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say – Law360 Tax Authority
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.
Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25.
Pillsbury SALT attorney Zachary Atkins will be presenting at the Southeastern Association of Tax Administrators 2023 Annual Conference on July 18 in Little Rock, Arkansas.
Congratulations to our Pillsbury SALT team, again earning recognition in the Chambers USA ranking guide. Our California SALT team earned a Band 1 ranking for the 3rd year, with partners Jeffrey Vesely (Band 1) earning his 17th ranking, Carley Roberts (Band 1) with her 15th ranking, and Robert Merten (Band 2) with his 1st ranking this year. Congratulations!
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.
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).
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 ›
Our state and local tax team comments on the New York State Division of Tax Appeals (DTA) administrative law judge (ALJ) determination that Raytheon Company and affiliates (Raytheon) did not qualify for New York’s zero percent tax rate for manufacturers or the reduced tax rate for qualified emerging technology companies (QETCs).
Read More: New York’s Zero Manufacturing Rate Requires New York Property (pillsburylaw.com)
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 ›
