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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!SALT-Chambers-2024-1024x576

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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.”

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The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source service receipts to New Jersey.  In its unpublished April 11, 2024, opinion, the court rejected the argument that the law and regulations in effect during the tax years at issue, which preceded 2018 legislation adopting market-based sourcing, required the use of a cost of performance (COP) methodology.

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Zack Atkins’ comments in Law360 Tax Authority regarding newly passed legislation in Tennessee that could provide taxpayers with up to $1.6 billion in rebates for portions of three years of past payments and up to $400 million in new savings each year.

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