The Pillsbury SALT team had a memorable time last week at COST’s 54th Annual Meeting in Las Vegas, NV. Carley Roberts, Zachary Atkins and Evan Hamme were all speakers during the annual meeting, and the rest of the team attended a variety of substantive sessions on SALT issues and state tax trends. On Wednesday evening, the team also hosted a unique and memorable client event in the SKYLOFTS at MGM Grand.
2023 Annual Meeting of the Tax Bar and Tax Policy Conference
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Join Jeff Phang, Jeff Vesely and Robert Merten on day two of the California Lawyers Association’s 2023 Annual Meeting of the Tax Bar and Tax Policy Conference, when they will each speak on separate panels.
9:40 – 10:40 AM Sourcing Income from Passthrough Entities & Developments Since Metropoulos – Jeff Phang
This panel will focus on the interplay between the California personal income tax law and the tax law for entities in the context of sourcing income—namely, income derived from an ownership interest in a pass-through entity or the sale of that ownership interest.
10:50 – 11:50 AM California Litigation Update – Robert Merten
This panel brings together well-known speakers from the Franchise Tax Board, California Department of Tax and Fee Administration and private practice for a candid overview of the important developments of SALT litigation on a national and state level.
1:45 – 3:15 PM Substantial and Occasional Developments in Alternative Apportionment for Corporate Income Tax – Jeff Vesely
This panel will discuss California’s alternative apportionment rules with a focus on the Substantial and Occasional Sale rule.
For more information or to register, please visit the event page.
Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business
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On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT)[1] including expanding the definition of what constitutes a “unitary business.” The expanded definition now includes affiliated entities that may not have previously met the requirements for combined group membership for CBT purposes. 
California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid
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A California trial court denied summary judgment in the American Catalog Mailers Association’s (ACMA) action that seeks to invalidate Franchise Tax Board (FTB) guidance that says certain online activities exceed the protections of Public Law 86-272 for state income tax purposes. However, the court signaled it may invalidate the FTB’s guidance on the basis it constitutes underground regulations and violates California’s Administrative Procedure Act.
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TEI’s 2023 Annual Conference
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Please join Pillsbury partner Jeff Vesely at TEI’s 2023 Annual Conference – a 75th Anniversary Celebration in New York City. Jeff will be participating on a panel titled, “State Tax Policy: As Deficits Return Will the Tide Change?” This conference will take place October 22 – 25 at the New York Marriott Marquis Hotel.
In celebration of the 75th anniversary of the Annual Conference, TEI has organized several special events designed to give participants a quintessential New York experience, such as pizza and architectural tours. These will be held before the conference begins.
The Annual Conference will feature a comprehensive program with nearly 40 sessions focused on U.S. federal, international and state and local tax, as well as Canadian tax, financial reporting and corporate tax management issues. In addition to this high-value content, the event will offer multiple opportunities to meet and connect with your fellow in-house tax professionals during networking breaks and social functions, visit with sponsors and speakers in the exhibit halls and sponsor events, and enjoy everything New York City offers!
For more information, please visit the event page.
COST’s 54th Annual Meeting
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Pillsbury attorneys Carley Roberts, Zachary Atkins, and Evan Hamme will present at COST’s 54th Annual Meeting in Las Vegas, NV.
Pillsbury SALT Recognized in Best Lawyers, 2024 edition
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Congratulations to our Pillsbury SALT team for earning recognition in the 2024 edition of Best Lawyers in America and Best Lawyers: Ones to Watch. 
Partner Jeffrey Vesely was recognized as a Lawyer of the Year in San Francisco for Litigation and Controversy – Tax.
Congratulations to all recognized!
Best Lawyers
Jeffrey Vesely (Lawyer of the Year)
Craig Becker
Carley Roberts
Ones to Watch
Christopher Koester
Taxation Without Representation: Michigan Supreme Court Says Neither State Law Nor the U.S. Constitution Requires Inclusion of Receipts From Deemed Asset Sale in Sales Factor
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In a split decision, the Michigan Supreme Court rejected a taxpayer’s assertion that applying the standard apportionment formula to gain derived from a deemed asset sale led to a grossly distorted, unconstitutional result. The court held in Vectren Infrastructu
re Services Corporation v. Department of Treasury, No. 163742 (July 31, 2023), that applying the standard single sales factor apportionment formula—which did not include any receipts from the deemed asset sale—to apportion the gain did not violate the U.S. Constitution’s Due Process Clause or Commerce Clause.
30th Annual Paul J. Hartman SALT Forum
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Join Carley Roberts and Evan Hamme during this upcoming SALT event. During the Forum, Carley will be part of a panel discussion on the application of the true object test and similar tests. Evan will appear on a panel looking at intercompany transactions and transfer pricing.
New Jersey Enacts Significant Changes to Corporation Business Tax Law
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On July 3, 2023, New Jersey Governor Phil Murphy signed A.B. 5323 into law to amend New Jersey’s Corporation Business Tax (CBT). The bill enacted a variety of clarifications, corrections and modifications to the CBT.