Pillsbury SALT partner Breann Robowski will present during ABA/IPT’s 2021 Advanced Property Tax Seminar on March 18.
COST’s 2021 Sales and Transaction Tax Webinar
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Pillsbury SALT partner Craig Becker will present during COST’s 2021 Sales and Transaction Tax Webinar on February 25. Craig is partnering with Harley Duncan (KPMG), Jordan Goodman (HMB) and Mark Yopp (Baker & McKenzie) to present on the topic, “Wrangling in Local Transaction Taxes.”
Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on “Convenience of the Employer” Rule
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The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take credits
for tax paid to other states while working from Connecticut during the pandemic. Connecticut law currently allows credits for tax paid to another state only if: (1) the individual was physically located in such other state while working; or (2) the individual is a resident of a state that applies the “convenience of the employer” sourcing rule. Two bills have been introduced, both of which would expand the allowable credits only for Connecticut residents and part-year residents for the tax year beginning January 1, 2020. H.B. 6183; S.B. 873. Continue Reading ›
TEI’s Wisconsin Chapter Meeting
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Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18.
Continue Reading ›
Should San Francisco Taxpayers File Protective Claims for Recovery of the Homelessness Tax and the Commercial Rents Tax?
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In 2018, San Francisco voters approved, by simple majority vote, two new gross receipts taxes: the Homelessness Gross Receipts Tax (SF-HT) and the Commercial Rents Tax (SF-CRT), with both 
taxes effective as of January 1, 2019.[1] Because these taxes fund specific governmental services, they are designated as special taxes (specifically, the SF-HT funds homelessness services and the SF-CRT funds early childhood education). Since the California Constitution specifies that special taxes imposed by local government need two-thirds voter approval (i.e., a “supermajority”), taxpayer groups have filed lawsuits to invalidate these special taxes, as both were approved by only a majority vote (61% for the SF-HT and 51% for the SF-CRT).[2] As discussed more fully below, the courts have ruled against these taxpayer groups and the California Supreme Court to date has refused review.
The pressing question is whether San Francisco taxpayers, who paid the SF-HT and/or the SF‑CRT for 2019 and 2020, should be filing claims to protect their rights to refunds in the unlikely (but not impossible) event that these taxes are ultimately rendered invalid.
New York Law Raises Property Tax Issues for the U.S. Nuclear Industry
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Nuclear fuel storage facilities have been impacted by a change in New York law, which requires facilities located at permanently shut down nuclear power plants to be assessed as real property for ad valorem tax purposes, leading to potential larger, national impacts. SALT team members Zachary T. Atkins, Breann E. Robowski, and Craig A. Becker team up with Pillsbury’s Energy attorneys to discuss.
California Alliance of Taxpayer Advocates Annual Conference
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Pillsbury SALT partner Breann Robowski will present during the California Alliance of Taxpayer Advocates Annual Conference taking place February 11-12, 2021. Breann is partnering with Troy Van Dongen (McDermott Will & Emery) and George Seikaly (San Diego County) to present on the topic, “Streamlining the AAB Process – Remote Hearings, Scheduling, Pre-hearing Procedure & Resolution” on Friday, February 12.
Transfer Tax and Distressed Real Estate: New York and California
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Real Estate markets in major cities have taken a hit given the events of the past year. In the latest Swimming Lessons Series presentation, SALT partner Craig Becker and Real Estate partner Andrew Weiner explore the intersection of transfer tax and enforcement in New York and California. Continue Reading ›
Attorney Spotlight: Breann Robowski
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Breann serves as an innovator and significant contributor at the California State Board of Equalization (BOE) meetings. She has testified at length at each of the BOE’s monthly meetings 
since September 2020 as a member of the Collaborative Workgroup on Remote Hearings—the task force created by the BOE to pioneer the implementation of virtual Assessment Appeals Board (AAB) hearings as an alternative to in-person hearings due to the safety concerns and conditions associated with the COVID-19 pandemic. Continue Reading ›
Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity
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A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions 
for members of federal consolidated groups, holding that the policy violated the Uniformity Clause of the state constitution. Verisign, Inc. v. Director of Revenue, No. N19C-08-093 JRJ (Del. Super. Ct. Dec. 17, 2020). The decision presents a potential refund opportunity for Delaware corporate taxpayers who were members of a federal consolidated group, and for Delaware corporate income tax purposes had their separate-company NOL deductions limited to the group’s consolidated NOL.
Pillsbury attorney Zack Atkins explains.
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