SeeSALT Blog

Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based Sourcing

Posted April 25, 2023

by Breanna N. Zagorski and Zachary T. Atkins

Breanna N. Zagorski

Zachary T. Atkins

Florida-300x300 On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes. In Billmatrix Corp. v. State of Florida, Department of Revenue, No. 2020-CA-000435 (Fla. 2d Cir. Ct. Mar. 1, 2023), the court strongly rebuked the Florida Department of Revenue for attempting to apply market-based sourcing in contravention of its own COP sourcing regulation. Continue Reading ›

2023 COST Intermediate/Advanced State Income Tax School

Posted April 13, 2023

by Pillsbury SALT

Pillsbury SALT

Pillsbury SALT attorney Evan Hamme will be presenting at the 2023 COST Intermediate/Advanced State Income Tax School on May 8 in DFW Airport, Texas.

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COST/CTC Mid-West Regional State Tax Seminar

Posted April 13, 2023

by Pillsbury SALT

Pillsbury SALT

Pillsbury SALT attorneys Carley Roberts, Craig Becker, Zachary Atkins and Kristen Sharp will be presenting at the upcoming COST/CTC Mid-West Regional State Tax Seminar on Wednesday, May 3 in Rolling Meadows, Illinois.

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TEI New York Chapter SALT Meeting

Posted March 29, 2023

by Pillsbury SALT

Pillsbury SALT

Pillsbury SALT attorneys Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present during TEI’s New York Chapter SALT Meeting on April 19 taking place at Pillsbury’s New York Office.

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California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

Posted March 21, 2023

by Craig A. Becker, Breann E. Robowski and Kristen Sharp

Craig A. Becker

Breann E. Robowski

Kristen Sharp

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (ACA 11) which proposes to abolish the State Board of Equalization (BOE) and reassign its responsibilities to other state tax agencies effective January 1, 2026. Continue Reading ›

Property Tax Rate Dispute Merits California Supreme Court Review

Posted March 20, 2023

by Craig A. Becker, Carley Roberts, Breann E. Robowski, Robert P. Merten III and Joseph Chan

For years, some California counties have been imposing disproportionately higher property tax rates on centrally assessed property despite the state constitutional mandate that this property be assessed like locally assessed property.

In a challenge brought by centrally assessed utilities, the California Court of Appeal conceded that the higher property tax rates disproportionally burden utility company property but concluded that this disparity does not violate the California Constitution.

Click here to read the full article.

UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms

Posted March 8, 2023

by Jeff Phang, Robert P. Merten III and Carley Roberts

Jeff Phang

Robert P. Merten III

Carley Roberts

In addition to the tax relief announced in January, the California Franchise Tax Board (FTB) has automatically extended the income tax filing and payment deadlines for businesses and individuals affected by severe winter storms in California until October 16, 2023.