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best-law-firms-badge-2020-300x300Pillsbury has earned a total of 154 national and regional practice rankings in the latest U.S. News – Best Lawyers 2020 Best Law Firms survey.

The Tax team’s rankings include:

To view Pillsbury’s complete list of practice rankings, click here.

The U.S. News – Best Lawyers Best Law Firms rankings are based on a rigorous evaluation process that includes the collection of client and lawyer evaluations, peer review from leading attorneys in the field, and review of additional information provided by law firms as part of the formal submission process. To be eligible for a 2020 ranking, a law firm must have at least one lawyer recognized in the 25th Edition of The Best Lawyers in America list for that particular location and specialty.

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Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III and Mike Le co-authored “Sunny State Shade: Arizona’s Objection to California’s Tax Reach” in a recent edition of SeeSALT Digest, by Tax Notes State. In this article, Carley, Robert and Mike evaluate and provide an update on Arizona’s judicial objection to the reach of California’s tax imposition on out-of-state companies whose only connection to California is a passive investment interest.

To read the article, please click here.

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New York State increased the sales tax economic factor presence nexus threshold from $300,000 to $500,000. The change is retroactive to June 1, 2019. Accordingly, marketplace providers with no physical presence in the state are required to register and collect New York sales tax if the provider’s gross receipts from sales of tangible personal property in New York is equal to or exceeds $500,000 and facilitated more than 100 sales of tangible personal property delivered in the state. The sales are computed over the past four sales tax quarters. It’s not clear what prompted the state to increase the gross receipts threshold of the economic nexus standard—there are no other changes to the definition of marketplace provider, marketplace sellers or to any of the liability relief provisions. (For more information, access the recently issued marketplace provider guidance here, and the prior guidance here.)

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The California Department of Tax and Fee Administration held an Interested Parties Meeting to address proposed regulation 1684.5 on marketplace sales. The proposed regulation defines terms used in the Marketplace Facilitator Act (added by AB 147), explains the registration requirements for marketplace facilitators and marketplace sellers, clarifies when a marketplace facilitator is the seller and retailer, and provides election procedures for a delivery network company to be deemed a marketplace facilitator. After the comment period closes on October 30, the Department will decide whether to proceed with formal rulemaking as authorized by the Marketplace Facilitator Act. The Department also has the authority to adopt emergency regulations through June 2020, which, if adopted, will remain in effect for two years.

The Department’s discussion paper can be found here.

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Ab8oGgo5_400x400-300x300There were two competing bills regarding tax sharing agreements (TSAs) this legislative session: SB 531 and SB 485. The former would have barred all TSAs at the local level as of January 1, 2020. The latter would not bar TSAs but instead would require the locality to report certain information pertaining to the agreement that would be made publicly available. On October 12, 2019, Gov. Gavin Newsom vetoed the bill that would have barred TSAs altogether and instead signed the other bill that requires publicly reporting certain information pertaining to the TSAs.

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FTB-logo-300x300Yesterday, the California Franchise Tax Board convened a public meeting to discuss tax compliance within the growing gig economy and the challenges of meeting these obligations. Speakers from academia, the FTB, the business community, and gig workers themselves, discussed various tax issues, three of which stood out.

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Caroline-Koo-Intro_SALT-social-media

Pillsbury SALT welcomes Senior Law Clerk Caroline Koo to our award-winning State & Local Tax team!

Caroline advises clients on all areas of state and local taxation, including multistate litigation, planning, audit defense, and controversy issues. She focuses on tax controversy, from audit defense through litigation, and also counsels on multistate tax planning and structuring matters.

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tei new yorkPillsbury is proud to partner with TEI’s NY Chapter to host their State & Local Chapter Meeting. Join Pillsbury SALT and TEI NY Chapter members for “Sales Tax: Transformation in Action.”

In a presentation designed for sales tax compliance professionals at all levels, Sheila Rao, Senior Vice President, TEI NY Chapter, will present a step-by-step study of her company’s sales tax software implementation.

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Nebraska-flag-logoNebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not qualify for the state’s dividends received deduction. Nebraska Dep’t of Revenue, Gen. Info. Letter 24-19-1 (Sept. 13, 2019).

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