Pillsbury partners Breann Robowski and Jorge Medina will be participating in the Wichita Property Tax Conference taking place on July 24-28.
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Wichita Property Tax Conference
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California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the Entity Level.
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The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s California apportionment formula and is not sourced 100 percent to the nonresident shareholder’s domicile. Continue Reading ›
Welcome to Pillsbury SALT, Jack!
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Pillsbury SALT is excited to welcome Jack Camillo to the team!
Jack’s experience includes multistate litigation, planning, audit defense, and controversy issues.
He joins Pillsbury’s New York office as an associate.
5 Questions with Jack: Continue Reading ›
New Tax Legislation Shifts Consolidated Return Landscape in Georgia
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Pillsbury SALT attorneys Zachary T. Atkins, Evan M. Hamme, Jack Thomas Camillo discuss new tax legislation in GA.
Takeaways 
- For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of Revenue.
- The principal benefit of filing a consolidated return is the ability to offset taxable income and losses.
- The election is irrevocable and binding for five years.
2022 Summer Tax Institute
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Pillsbury SALT partner Robert P. Merten III will be participating as an instructor in the 2022 Summer Tax Institute put on by the UC Davis School of Law.
2022 CalTax Foundation Webinar Series
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Pillsbury SALT partner Breann Robowski will participate in the CalTax webinar series on June 7.
CalTax’s 96th Annual Meeting
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Pillsbury SALT partner Carley Roberts will be participating in a panel discussion on income tax at the CalTax Annual Meeting on June 2. 
Broker-Dealer Successfully Fights Look-Through Sourcing in New York
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An administrative law judge in the New York State Division of Tax Appeals rejected the New York State Division of Taxation’s use of a look-through approach for sourcing fees paid to a broker-dealer for marketing, recordkeeping, and support services. The April 28, 2022 determination in Matter of TD Ameritrade, Inc., confirms that such fees are properly sourced to the location of the customer responsible for payment, in this case two banks. 
COST’s SALT School Programs
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Pillsbury SALT Counsel Evan Hamme will be an instructor at the COST Intermediate and Advanced Income Tax School scheduled for May 15-19, 2022.
COST’s Intermediate and Advanced Income Tax School is being held simultaneously with COST’s SALT Basics School and Intermediate and Advanced Sales and Use Tax School in Atlanta, GA. These programs provide learning opportunities for attendees to explore and gain a deeper understanding of SALT Income and Sales and Use Tax issues. Continue Reading ›
Texas Supreme Court Sides with Sirius XM’s “Straightforward” Interpretation of Service Receipt Sourcing Statute
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The Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision resolves disagreement regarding the proper interpretation of a Texas franchise tax apportionment statute that addresses the sourcing of service receipts. The statute sources a service provider’s receipts to Texas to the extent the service is “performed” in Texas. The taxpayer argued that its receipts from sales of satellite radio programming subscriptions were properly sourced to the location where its personnel and equipment performed the radio production and transmission services necessary for its radio programming (“origination sourcing”). The Comptroller interpreted the apportionment statute to source service receipts to Texas if the “receipt-producing, end-product act” takes place in Texas, which the Comptroller argued occurred where each subscriber’s radio received and decrypted the taxpayer’s radio signal (“destination sourcing”).