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Recent Ohio Supreme Court decisions addressing the situsing of receipts under the Commercial Activity Tax (CAT) underscore both the limits of the “continuous delivery theory” and the evidentiary hurdles taxpayers face when seeking refunds for transactions involving Ohio distribution centers.image-removebg-preview-5-298x300 Read together, VVF Intervest, L.L.C. v. Harris, Slip Op. No. 2025-Ohio-5680 (Ohio Dec. 24, 2025), and Jones Apparel Group/Nine West Holdings v. Harris, Slip Op. No. 2026-Ohio-74 (Ohio Jan. 14, 2026), confirm a transaction-focused approach to CAT situsing while highlighting the evidentiary showing required to substantiate refund claims.

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Pillsbury SALT is excited to welcome Lauren Durborow to the team!

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Lauren’s experience includes variety of state and local tax matters, including multistate litigation, planning, audit defense and controversy issues.

She joins Pillsbury’s New York office as an associate.

5 Questions with Lauren: Continue Reading ›

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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.

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A recent Bloomberg Law article suggests the coming year could bring pivotal state and local tax rulings with implications that extend well beyond the individual disputes.Bloomberg-Tax-Logo-300x157

Pending cases in New York, South Carolina and Maryland raise key questions involving foundational state tax issues that SALT practitioners will be watching closely in 2026.

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In a recent article published by TaxNotes, our colleague Andrew Weiner commented on New York Governor Kathy Hochul’s veto of legislation that would have decoupled the state’s LLC Transparency Act from the federal Corporate Transparency Act.Tax-Notes-logo-300x212

The veto keeps New York’s beneficial ownership disclosure regime aligned with the narrowed federal rules, raising state and local tax–related compliance and administrative questions for foreign-formed and multistate LLCs doing business in New York. The article discusses the resulting uncertainty, including the absence of state guidance and the potential for ongoing state-level filing obligations that do not exist under federal law. 

 To read more (article behind TaxNotes paywall): New York Tied to Narrowed Scope of Federal Corporate Transparency Act | Tax Notes

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Proponents of the 2026 Billionaire Tax Act amended the initiative, prompting opponents to file five new initiatives aimed at undermining various aspects of the measure. The 2026 Billionaire Tax Act would impose a one-time wealth tax on California residents and trusts with “net worth,” defined in the initiative, exceeding $1 billion, as discussed more detail in our prior article.

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