Pillsbury SALT partner Robert P. Merten III will present at a tax policy seminar hosted by the California Lawyers Association on October 18.
Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs
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The Arizona Court of Appeals held that an investment tax credit (ITC)
deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property tax purposes. In so holding, the court rejected the argument that an ITC has no monetary worth until its owner derives an actual economic benefit from the ITC, i.e., by using it to reduce a federal income tax liability.
Pillsbury SALT Team Together in California for COST Tech
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The Pillsbury SALT team had an incredible time last month at the COST SALT Workshop for Technology Companies in Cupertino, CA. Carley Roberts, Zachary Atkins, Craig Becker, Evan Hamme, Robert P. Merten III, Jeffrey Vesely, and Aruna Chittiappa were all panelists and presented on various topics at the workshop. The team also participated in SALT group meetings held at Pillsbury’s Palo Alto office. Over the course of several days we learned more about each other, strategized ways to better serve our clients, and attended a variety of substantive sessions.
Pillsbury SALT recognized in Best Lawyers 2025
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Congratulations to our Pillsbury SALT team for earning recognition in the 2025 edition of Best Lawyers in America.
Partner Craig Becker was recognized as a Lawyer of the Year in San Jose for Litigation and Controversy – Tax.
Congratulations to all recognized!
Best Lawyers
Craig Becker (Lawyer of the Year)
Carley Roberts
Jeffrey Vesely
Technology Transfer Agreements: Latest Developments in California
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In 1993, the California Legislature amended Revenue and Taxation Code (RTC) sections 6011 and 6012 to exclude from California sales and use tax amounts charged for intangible personal property transferred with a technology transfer agreement (TTA) if the TTA separately stated a reasonable price for the tangible personal property (TPP). Nine years later, the State Board of Equalization (SBE) adopted Regulation 1507, Technology Transfer Agreements, to implement and interpret the TTA statutes and to incorporate the California Supreme Court’s holding in Preston v. State Board of Equalization, 25 Cal.4th 197 (2001). Subsequent litigation over the next 13 years in Nortel Networks, Inc. v. State Board of Equalization, 191 Cal.App.4th 1259 (2011) and Lucent Technologies, Inc. v. State Board of Equalization, 241 Cal.App.4th 19 (2015), invalidated portions of Regulation 1507, as well as Regulation 1502 (Computers, Programs and Data Processing). In the nine years since the Lucent decision, the SBE and its successor, the California Department of Tax and Fee Administration (CDTFA), have been engaged in a seemingly endless regulation project.
Pillsbury SALT recognized in Legal 500 2024
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Congratulations to our Pillsbury Winthrop Shaw Pittman LLP SALT team for earning recognition in the Legal 500 US ranking guide. The California SALT team earned a Band 5 ranking for US Taxes – Contentious. Congratulations!
COST’s 2024 Annual Meeting
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Pillsbury SALT attorneys Evan Hamme and Aruna Chittiappa will present during COST’s Annual Meeting on September 25 and 26.
CalTax Foundation Webinar
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Pillsbury SALT partner Carley Roberts will participate as a panelist on an upcoming CalTax Foundation webinar on Tuesday, September 10.
Pillsbury SALT recognized in Chambers USA 2024
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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 4th year, with partners Jeffrey Vesely (Band 1) earning his 18th ranking, Carley Roberts (Band 1) with her 16th ranking, and Robert Merten (Band 2) with his 2nd ranking this year. Congratulations!
Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity
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The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carve-out language regarding the term “unitary corporation.”