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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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.
Pillsbury attorneys Carley Roberts, Zachary Atkins, and Evan Hamme will present at COST’s 54th Annual Meeting in Las Vegas, NV.
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
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.
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.
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.
Pillsbury SALT attorney Zachary Atkins was quoted in the Law360 article “Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say” from his presentation during the Southeastern Association of Tax Administrators 2023 Annual Conference on July 18.
Read more: Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say – Law360 Tax Authority
The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales terms obtained from Minnesota customers by the company’s salespeople.
Pillsbury SALT partner Breann Robowski will be speaking at the Wichita Property Tax Conference on July 25.
