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The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take creditsct-150x150 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 ›

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Partner Carley Roberts and counsel Robert Merten III authored Part 1 of a multi-part series in Tax Notes State’s SeeSALT Digest to review the landscape of market-based sourcing rules and provide an in-depth focus on various states’ use of reasonable approximation.

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Read more here. Continue Reading ›

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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 Seal_of_San_Franciscotaxes 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.

Continue Reading ›

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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, Craig A. Becker, and Marc A. Simonetti team up with Pillsbury’s Energy attorneys to discuss.

https://seesalt.pillsburylaw.com/files/2020/04/Seal_of_New_York.svg_-300x300.png Continue Reading ›

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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.

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Continue Reading ›

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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 ›

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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 Robowski1-1024x576since 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 ›

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A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions Verisign-DE-300x180for 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 attorneys Marc Simonetti and Zack Atkins explain.

To read the full article, please click here.

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