The Pennsylvania Governor signed H.B. 1342 to enact changes to the state’s corporate income tax.[1]
The legislation modifies the corporate income tax in three ways: (1) adopts a bright-line economic nexus standard; (2) adopts market sourcing for receipts from intangibles; and (3) reduces the corporate tax rate and gradually continues to reduce the rate over the next eight years. Continue Reading ›
Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions
Our federal tax colleagues analyzed the corporate tax provisions in the Inflation Reduction Act, including the 15-percent minimum tax on corporations and the excise tax on stock buybacks.

Read More: Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions (pillsburylaw.com)
New Jersey Supreme Court Requires Factual Record in Jersey City Payroll Tax Dispute
The New Jersey Supreme Court upheld a lower court decision that Jersey City’s payroll tax
was not a facial violation of the U.S. Constitution but remanded the matter to create a factual record to evaluate an as-applied challenge to the tax.
Enacted in 2018, the Jersey City payroll tax applies to employers with payroll exceeding $2,500 in any calendar quarter and is based on the employer’s nonresident employee payroll sourced to Jersey City. The payroll tax statute sources a nonresident employee’s payroll to Jersey City if the employee works in or is supervised from Jersey City. Continue Reading ›
Wichita Property Tax Conference
Pillsbury partners Breann Robowski and Jorge Medina will be participating in the Wichita Property Tax Conference taking place on July 24-28.
Continue Reading ›
California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the Entity Level.
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!
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
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 CalTax Foundation Webinar Series
Pillsbury SALT partner Breann Robowski will participate in the CalTax webinar series on June 7.

CalTax’s 96th Annual Meeting
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
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. 


