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!








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. 
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. 
