Publications

12/09/24	“California OTA Denies Credit for NYC Business Taxes in Precedential Opinion” SeeSALT Blog Post Authors: Carley Roberts, Robert P. Merten III, Jeff Phang, Taylor A.F. Wolff
11/11/24	“California Imposes Further Disclosure Requirements for Local Sales Tax Sharing Agreements” SeeSALT Blog Post Authors: Robert P. Merten III, Aruna Chittiappa, Nolan Kessler
10/07/24	“California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16” SeeSALT Blog Post Authors: Carley Roberts, Robert P. Merten III, Jeff Phang
09/25/24	“Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs” SeeSALT Blog Post Authors: Zachary Atkins, Craig Becker
08/26/24	“Technology Transfer Agreements: Latest Developments in California “ Pillsbury Client Alert Authors: Jeffrey Vesely, Richard Nielsen
08/07/24	“Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity” SeeSALT Blog Post Authors: Robert P. Merten III, Taylor A.F. Wolff
07/10/24	“New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing” SeeSALT Blog Post Authors: Jack Camillo, Zachary Atkins
06/05/24	“California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization” SeeSALT Blog Post Authors: Carley Roberts, Jeffrey Vesely, Robert P. Merten III, Jeff Phang
05/09/24	“Proposed Initiative to Amend San Francisco Business Taxes” SeeSALT Blog Post Authors: Jeffrey Vesely, Richard Nielsen
05/06/24	“New Jersey Issues Guidance on Adoption of Federal Partnership Audit Regime” SeeSALT Blog Post Authors: Taylor A.F. Wolff, Robert P. Merten III
04/22/24	“South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department” SeeSALT Blog Post Authors: Breanna Zagorski, Zachary Atkins
04/04/24	“Reminder: ‘Gross’ Does Not Mean ‘Net’ – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor” SeeSALT Blog Post Authors: Carley Roberts, Robert P. Merten III, Jeff Phang. Nolan Kessler
03/20/24	“Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes” SeeSALT Blog Post Authors: Jeff Phang, Robert P. Merten III, Carley Roberts
03/04/24	“Got Remote Workers? Supreme Court of Ohio Upholds Pandemic Rule for Municipality Tax” SeeSALT Blog Post Authors: Taylor A.F. Wolff, Robert P. Merten III
02/15/24	“California Trial Court Denies FTB’s Motion to Vacate and Modify Judgment that Declared Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid” SeeSALT Blog Post Authors: Jeffrey Vesely, Carley Roberts, Nolan Kessler
02/06/24	“New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operation Location” SeeSALT Blog Post Authors: Evan Hamme, Breanna Zagorski
01/22/24	“Try, Try Again – New York’s Convenience of the Employer Rule Sources Nonresident Wages to New York Even During the Pandemic” SeeSALT Blog Post Authors: Evan Hamme, Jack Camillo
01/08/24	“California Credit Claim Denials – California Office of Tax Appeals Issues Two Opinions Rejecting Taxpayers’ Submitted Evidence to Substantiate Claimed California Research and Development Tax Credits” SeeSALT Blog Post Authors: Nolan Kessler, Robert P. Merten III
12/20/23	“California Trial Court Grants Industry Trade Association’s Motion for Summary Adjudication, Declaring Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid” SeeSALT Blog Post Authors: Jeffrey Vesely, Carley Roberts, Nolan Kessler
12/11/23	“Maine Expressly Requires Express Scripts to Apportion Services Receipts Using a Look-Through Approach” SeeSALT Blog Post Authors: Taylor A.F. Wolff, Robert P. Merten III
11/13/23	“No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01” SeeSALT Blog Post Authors: Robert P. Merten III, Jack Camillo
10/09/23	“Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business” SeeSALT Blog Post Authors: Aruna Chittiappa, Taylor A.F. Wolff
09/21/23	“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” SeeSALT Blog Post Authors: Jeffrey Vesely, Carley Roberts, Nolan Kessler
08/21/23	“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” SeeSALT Blog Post Authors: Breanna Zagorski, Zachary Atkins
08/07/23	“New Jersey Enacts Significant Changes to Corporation Business Tax Law” SeeSALT Blog Post Authors: Evan Hamme, Taylor A.F. Wolff
07/12/23	“Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection” SeeSALT Blog Post Authors: Joseph Chan, Robert P. Merten III
05/31/23	“A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain ‘Qualified Tangible Personal Property'” Pillsbury Client Alert Authors: Carley Roberts, Craig Becker, Richard Nielsen, Zachary Atkins
05/24/23	“New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts from ADSL and Fiber Broadband Sales” SeeSALT Blog Post Authors: Zachary Atkins, Christopher Koester
05/17/23	“No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit” SeeSALT Blog Post Authors: Carley Roberts, Jeff Phang
05/01/23	“‘If You Don’t Make It There, You Can’t Make It Anywhere:’ New York’s Zero Manufacturing Rate Requires New York Property” Pillsbury Client Alert Authors: Marc Simonetti, Evan Hamme, Christopher Koester, Breanna Zagorski
04/25/23	“Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based Sourcing” SeeSALT Blog Post Authors: Zachary Atkins, Breanna Zagorski
03/21/23	“California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization” SeeSALT Blog Post Authors: Craig Becker, Breann Robowski, Kristen Sharp
03/08/23	“UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms” SeeSALT Blog Post Authors: Jeff Phang, Robert P. Merten III, Carley Roberts
02/13/23	“Property Tax Rate Dispute Merits California Supreme Court Review” Tax Notes State Authors: Craig Becker, Carley Roberts, Breann Robowski, Robert P. Merten III, Joseph Chan
02/08/23	“California Proposes Significant Revisions to Sales & Use Tax Statistical Sampling Audit Policies and Procedures” SeeSALT Blog Post Authors: Richard Nielsen, Nolan Kessler, Carley Roberts
01/31/23	“Texas Comptroller Takes a Serious Look at Sourcing Regulation After SiriusXM Loss” SeeSALT Blog Post Authors: Zachary Atkins, Taylor A.F. Wolff
01/23/23	“Recent Measures Establish Unprecedented Tax Increases on Real Property in California Cities” Pillsbury Client Alert Authors: Craig Becker, Breann Robowski, Rachel Horsch, David Wright
01/23/23	“California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms” SeeSALT Blog Post Authors: Jeff Phang, Robert P. Merten III, Carley Roberts
01/11/23	“Maryland Digital Ad Tax Updates: Comptroller Seeks Stay of State Court Decision Striking Tax and Recently Dismissed Federal Challenge is Under Appeal” SeeSALT Blog Post Authors: Aruna Chittiappa, Breanna Zagorski
11/30/22	“Second Place is Just the First Place Loser: Ohio Supreme Court Rejects State’s Sourcing of NASCAR Intangible Receipts to Ohio” SeeSALT Blog Post Authors: Zachary Atkins, Christopher Koester
11/28/22	“Texas Court of Appeals Confirms Cost-of-Performance Method is Proper to Source Service Receipts” SeeSALT Blog Post Authors: Carley Roberts, Evan Hamme, Taylor A.F. Wolff
11/02/22	“Three Strikes, You’re Out! New York Has Another Miss in Sales Tax Case Against a Service Provider Under the ‘Primary Function’ Test” SeeSALT Blog Post Authors: Marc Simonetti, Taylor A.F. Wolff
10/25/22	“‘Primary Function’ Test Propels Yet Another Service Provider to Victory in New York Sales Tax Case” SeeSALT Blog Post Authors: Zachary Atkins, Breanna Zagorski
10/24/22	“The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules” SeeSALT Blog Post Authors: Carley Roberts, Jeff Phang
10/21/22	“Maryland Court Invalidates Maryland’s First-of-Its-Kind Digital Ad Tax” SeeSALT Blog Post Authors: Marc Simonetti, Evan Hamme, Aruna Chittiappa, Christopher Koester
10/18/22	“The Curious First Meeting of the MTC’s Model Receipts Sourcing Regulations Work Group” Pillsbury Client Alert Authors: Zackary Atkins, Jeff Phang, Nolan Kessler
10/18/22	“Everything in its Place: New Mexico Hearing Officer Finds Markup for Out-of-State Service is Exempt, While Reimbursements for New Mexico Employee Payroll are Taxable” SeeSALT Blog Post Authors: Evan Hamme, Breanna Zagorski
10/10/22	“Industry Trade Association Sues California Franchise Tax Board Over “Radical” New Interpretation on Scope of Public Law 86-272 Post-Wayfair” SeeSALT Blog Post Authors: Robert P. Merten III, Carley Roberts, Nolan Kessler
08/30/22	“Pennsylvania Legislation Provides Updates to Corporate Income Tax Law” SeeSALT Blog Post Authors: Evan Hamme, Jack Camillo
07/21/22	“New Jersey Supreme Court Requires Factual Record in Jersey City Payroll Tax Dispute” SeeSALT Blog Post Authors: Evan Hamme, Taylor A. F. Wolff
06/09/22	“California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the Entity Level” SeeSALT Blog Post Authors: Carley Roberts, Jeff Phang
05/12/22	“New Tax Legislation Shifts Consolidated Return Landscape in Georgia” Pillsbury Client Alert Authors: Zachary Atkins, Marc Simonetti, Evan Hamme, Jack Camillo
05/09/22	“Broker-Dealer Successfully Fights Look-Through Sourcing in New York” SeeSALT Blog Post Authors: Zachary Atkins, Taylor A. F. Wolff
03/29/22	“Texas Supreme Court Sides with Sirius XM’s ‘Straightforward’ Interpretation of Service Receipt Sourcing Statute” SeeSALT Blog Post Authors: Carley Roberts, Evan Hamme, Taylor A. F. Wolff
02/15/22	“Contractual Delivery Terms Control Application of Alabama’s Wholesale Oil License Fee” SeeSALT Blog Post Authors: Carley Roberts, Lexi Louderback
02/10/22	“California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by 2020 Legislation” SeeSALT Blog Post Authors: Robert P. Merten III, Jeff Phang
02/09/22	“Trade Groups Ask SCOTUS to Hear Commerce Clause Challenge to Washington B&O Surtax on Financial Institutions” SeeSALT Blog Post Authors: Zachary Atkins, Aruna Chittiappa
12/29/21	“California Supreme Court Addresses Exhaustion of Administrative Remedies in Context of Proposition 218 BID Assessments” SeeSALT Blog Post Author: Richard Nielsen
12/20/21	“How to Be Reasonable When Reasonably Approximating the Market: Part II” Tax Notes State, Vol. 102, No. 12 Authors: Carley Roberts, Robert P. Merten III, Jeff Phang and Lexi Louderback
10/14/21	“Washington Supreme Court Upholds B&O Surtax on Financial Institutions” SeeSALT Blog Post Authors: Zachary Atkins, Aruna Chittiappa, Melissa Libutti
10/07/21	“California Governor Vetoes Sales Tax Bill Seeking to Require Large Online Retailers to File Informational Reports Detailing Sales by Destination” SeeSALT Blog Post Authors: Carley Roberts, Robert Merten III, Jeff Phang
09/20/21	“Taxpayer Files Court Action Challenging California’s Proposition 39 (2012) and its Mandatory Single-Sales Factor Apportionment Formula” SeeSALT Blog Post Authors: Carley Roberts, Robert Merten III, Jeff Phang
09/13/21	“CDTFA Proposes Amendments to Regulation 1706 (Drop Shipments) to Clarify that Marketplace Sales Are Generally Not Drop Shipment Transactions” SeeSALT Blog Post Author: Richard Nielsen
09/10/21	“California’s Long-Awaited Market-Based Sourcing Regulation Amendments: Why Participate in the Formal Regulatory Process?” SeeSALT Blog Post Author: Carley Roberts
09/09/21	“West Virginia: Streaming Services Subject to Sales and Use Tax” SeeSALT Blog Post Authors: Nicole Boutros, Caroline Koo
08/12/21	“Only Simple Majority Required (Again!): California Court of Appeal Holds SF’s Proposition G Citizen Initiative Did Not Require Supermajority Voter Approval; Reconsideration Request Pending” SeeSALT Blog Post Authors: Robert Merten III, Lexi Louderback
08/11/21	“California Court of Appeal Says Tax for ‘Public Safety Services’ and ‘Other Essential Services’ Not a Special Tax” SeeSALT Blog Post Authors: Carley Roberts, Lexi Louderback
06/28/21	“Massachusetts High Court Approves of Apportionment of Sales Tax on Software Through General Abatement Process” SeeSALT Blog Post Authors: Zachary Atkins, William Bennett
06/07/21	“U.S. Solicitor General Recommends the Supreme Court Decline New Hampshire v. Massachusetts” SeeSALT Blog Post Authors: Marc Simonetti, Evan Hamme, Melissa Libutti
05/05/21	New York Law Authorizing Taxation of Spent Nuclear Fuel Storage Facilities Raises Property Tax Issues for the U.S. Nuclear Industry Pratt’s Energy Law Report Authors: Zachary Atkins, Breann Robowski, Craig Becker, Marc Simonetti, Jay Silberg, and Jeffrey Merrifield
04/19/21	“San Francisco’s New Tax Provisions May Have Unintended Consequences” Tax Notes State Authors: Craig Becker, Breann Robowski, Richard Nielsen, Robert Merten III
04/15/21	“Tennessee Creates New Tax Benefits for the Film and Television Industry” SeeSALT Blog Post Authors: Zachary Atkins, Melissa Libutti
04/15/21	“New York Budget Raises Tax Rates, Provides Relief to Address Pandemic” Pillsbury Client Alert Authors: Marc Simonetti, Evan Hamme, William Bennett, Aruna Chittiappa
04/14/21	“Hidden Within The Transparency and Fairness Act of 2017 Was The Little Noticed Exemption from OAL Review of the CDTFA’s Proposed Regulations” SeeSALT Blog Post Authors: Annie Huang, Richard Nielsen
04/08/21	“Maryland Court of Appeals Rejects First Amendment Challenge to Local Tax on Outdoor Advertising Services” SeeSALT Blog Post Authors: Zachary Atkins, Aruna Chittiappa
03/29/21	“Oregon Tax Court Rejects Department’s Attempt to Ignore Measure 50 Limitation” SeeSALT Blog Post Authors: Zachary Atkins, Caroline Koo
03/10/21	“Delaware Court Invalidates Division’s NOL Limitation Policy” Tax Notes State Authors: Marc Simonetti, Zachary Atkins, Caroline Koo
02/26/21	“Maryland Becomes First U.S. State to Enact Controversial Digital Advertising Tax to Immediate Challenge” SeeSALT Blog Post Authors: Marc Simonetti, Aruna Chittiappa, Nicole Boutros
02/11/21	“Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on ‘Convenience of the Employer’ Rule” SeeSALT Blog Post Author: Evan Hamme
02/05/21	“How to Be Reasonable When Reasonably Approximating the Market: Part I” Tax Notes State Authors: Carley Roberts, Robert Merten III, Malcolm Brudigam
02/04/21	“Should San Francisco Taxpayers File Protective Claims for Recovery of the Homelessness Tax and the Commercial Rents Tax?” SeeSALT Blog Post Authors: Craig Becker, Breann Robowski, Richard Nielsen, Robert Merten III, Connor Corbitt
01/29/21	“New York Law Authorizing Taxation of Spent Nuclear Fuel Storage Facilities Raises Property Tax Issues for the U.S. Nuclear Industry” Pillsbury Client Alert Authors: Craig Becker, Jeffrey Merrifield, Jay Silberg, Marc Simonetti, Breann Robowski, Zachary Atkins
01/07/21	“Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity” SeeSALT Blog Post Authors: Marc Simonetti, Zachary Atkins, Caroline Koo
11/23/20	“Indiana Municipalities’ Franchise Fee Lawsuit Against Online Video Providers Remanded to State Court” SeeSALT Blog Post Authors: Zachary Atkins
11/09/20	“California’s Proposition 15 Is Failing While San Francisco Accepts a Bevy of Local Tax Measures” Pillsbury Client Alert Authors: Craig Becker, Breann Robowski, William Bennett
10/26/20	“Washington Supreme Court Asked to Review and Overturn Lower Court Decision Invalidating B&O Surtax on Large Financial Institutions” SeeSALT Blog Post Authors: Zachary Atkins, Aruna Chittiappa
08/31/20	“Cold Class Action: Federal Judge in Alaska Rules State and Local Sales Tax Class Action Survives Motion to Dismiss/Strike” SeeSALT Blog Post Authors: Robert Merten III and Malcolm Brudigam
08/26/20	“Pennsylvania’s Agency Deference Bait and Switch: Synthes USA” Tax Notes State Authors: Evan Hamme and Caroline Koo
08/24/20	“New York Trial Court Finds State’s Attempt to Tax Storage Services Performed Entirely in New Jersey Arbitrary and Capricious” SeeSALT Blog Post Authors: Zachary Atkins and Aruna Chittiappa
08/06/20	“California Court of Appeal Concludes That a Trust With a Non-California Trustee May Be Subject to Tax on All of Its Gain from the Sale of Stock” SeeSALT Blog Post Authors: Jeffrey Vesely and Annie Huang
07/30/20	“D.C. Council Abandons Digital Advertising Sales Tax Proposal” SeeSALT Blog Post Author: Aruna Chittiappa
06/29/20	“The Split-Roll Initiative Is Poised to Rock California’s Property Tax System” SeeSALT Blog Post Authors: Craig Becker, Richard Nielsen, Breann Robowski
06/29/20	“California Court of Appeal Concludes Transfer Tax Not Applicable to Purchase of Realty Encumbered by Long-Term Leasehold” SeeSALT Blog Post Authors: Craig Becker, Breann Robowski, Richard Nielsen, Robert Merten III
06/24/20	“California Legislature Passes Governor Newsom’s Proposal to Suspend California Net Operating Loss Deductions and Limit Tax Credits during 2020-2022” SeeSALT Blog Post Authors: Jeffrey Vesely, Craig Becker, Carley Roberts, Breann Robowski
06/09/20	“Appellate Court Says DREs Are Regarded for Tennessee Excise Tax Purposes When Owned by Noncorporate Parent; in Related News, S Corporation Rejoice” SeeSALT Blog Post Authors: Zachary Atkins, William Bennett
05/28/20	“Washington Judge Rules In Favor of Financial Institutions – B&O Tax Measure Discriminates Against Out-of-State Banks” SeeSALT Blog Post Authors: Marc Simonetti, Aruna Chittiappa
05/27/20	“South Carolina Property Tax Law Discriminates Against Railroads in Violation of 4R Act” SeeSALT Blog Post Author: Zachary Atkins
05/18/20	“California Supermajority Tax Challenge Cases are Onto the Next Level: Last Trial Court Ruling Issued” SeeSALT Blog Post Author: Robert Merten III
05/15/20	“Mississippi Supreme Court Holds Tolling Provision Applies to Department, Not Taxpayers” SeeSALT Blog Post Author: Zachary Atkins
04/30/20	“OTA Rules in Precedential Opinion Taxpayer Entitled to Interest Abatement Due to FTB’s Delays in the Protest Process” SeeSALT Blog Post Author: Carley Roberts
04/30/20	“Limiting Locality Profiteering: New Hampshire Supreme Court Strikes Down State Statute Permitting Localities to Profit from Sales of Seized Tax-Delinquent Properties” SeeSALT Blog Post Author: Robert Merten III
04/13/20	“COVID-19: Comprehensive Coverage of State Income Tax Relief as of April 13, 2020” SeeSALT Blog Post Authors: Carley Roberts, Robert Merten III, and Afshin Michael Khazaeli
04/08/20	“New York FY 2021 Budget Bill Decouples from CARES Act Taxpayer Relief Provisions” SeeSALT Blog Post Authors: Marc Simonetti & Aruna Chittiappa
04/07/20	“Missouri Supreme Court Ends Longstanding Practice of Applying Use Tax Definitions in Sales Tax Cases” SeeSALT Blog Post Author: Zachary Atkins
03/31/20	“Oregon Tax Court Applies Wayfair Retroactively in Telecommunications Tax Case” SeeSALT Blog Post Author: Jeffrey Vesely
03/30/20	“COVID-19: Comprehensive Coverage of State Income Tax Relief as of March 29, 2020” SeeSALT Blog Post Authors: Carley Roberts & Robert Merten III
03/26/20	“San Francisco’s COVID-19 Pandemic ‘Relief'” SeeSALT Blog Post Author: Robert Merten III
03/26/20	“No Sales or Use Tax Due on Materials and Equipment Used to Construct and Install Steam Facility at Tennessee Manufacturing Plant” SeeSALT Blog Post Author: Zachary Atkins
03/25/20	“California OTA to Host Informal IPM to Discuss Possible Amendments to Rules for Tax Appeals” SeeSALT Blog Post Author: Carley Roberts
03/21/20	“COVID-19: IRS and States Extend Tax Payment Deadlines” Pillsbury Client Alert Authors: Nora Burke, Hannah Hollingsworth, Carley Roberts, Mike Le
03/16/20	“Michigan Alternative Apportionment Formula Victory for Taxpayer” SeeSALT Blog Post Author: Jeffrey Vesely
03/06/20	“New Mexico Court of Appeals Upholds Refund Claim Dismissal for Taxpayer’s Violation of Discovery Order” SeeSALT Blog Post Author: Evan Hamme
02/27/20	“Arizona Advances Legislation Requesting Federal Intervention for Sales Tax Simplification” SeeSALT Blog Post Author: Caroline Koo
02/26/20	“Washington B&O Tax Litigation Hits Financial Services Industry” SeeSALT Blog Post Author: Aruna Chittiappa
02/06/20	“Massachusetts Supreme Judicial Court Upholds Massachusetts Sales Tax on Screen-Sharing Software Products” SeeSALT Blog Post Author: Zachary Atkins
01/31/20	“Illinois Taxpayers Score Rare TIA Win in Property Tax Dispute” SeeSALT Blog Post Author: Zachary Atkins
01/30/20	“No Dealer Here: Walmart Walks Away with Big Marketplace Facilitator Win in Creole State” SeeSALT Blog Post Author: Carley Roberts
01/17/20	“Solicitor General Argument Likely Dooms Arizona Tax Case at High Court” Law360 Author: Robert Merten III and Mike Le
01/16/20	“Washington Denies ‘Human Effort’ Exclusion to Online Research Service” SeeSALT Blog Post Author: Marc Simonetti
01/09/20	“New York Appellate Division Rejects Retroactive Application of Tax Law” SeeSALT Blog Post Authors: Marc Simonetti and William Bennett
12/12/19	“The CAT is Almost Out of the Bag! Oregon Releases First Set of Draft CAT Rules” Pillsbury Client Alert Authors: Carley Roberts and Robert Merten III
11/11/19	“‘Interactive’ Website Will Defeat P.L. 86-272 Immunity If the MTC Has Its Way” SeeSALT Blog Post Authors: Pillsbury SALT
10/28/19	“NYS Tax Department: Changes to Sales Tax Collection Requirement for Marketplace Providers” SeeSALT Blog Post Author: Aruna Chittiappa
10/28/19	“Navigating Local Labyrinths: Practitioners’ Guide to Local Taxes” Tax Notes State Author: Carley Roberts
10/15/19	“California Governor Vetoes Ban Against Tax Sharing Agreements and Signs New Law Requiring Certain Public Information for Disclosure” SeeSALT Blog Post Author: Carley Roberts
10/07/19	“Sunny State Shade: Arizona’s Objection to California’s Tax Reach” Tax Notes State Authors: Carley A. Roberts, Robert P. Merten III and Mike Le
10/02/19	“The California Franchise Tax Board Convenes a Public Meeting on the Gig Economy” SeeSALT Blog Post Authors: Pillsbury SALT
09/19/19	“Nebraska Clarifies Treatment of IRC 965 Repatriation Income” SeeSALT Blog Post Author: Marc Simonetti
09/09/19	“California OTA Rejects FTB’s 0.2 Percent Bright-Line Nexus Standard for Out-Of-State Minority Interest LLC Members” SeeSALT Blog Post Authors: Pillsbury SALT
08/30/19	“California Appellate Court Holds Abercrombie Sought to Create Rather than Eliminate Discriminatory Tax Reporting Treatment” SeeSALT Blog Post Author: Robert Merten III
08/22/19	“California Prop C Taxpayers Should File Protective Refund Claims” Law360 Authors: Richard Nielsen and Robert Merten III
08/19/19	“NYS ‘Service’ vs. ‘Other Business Receipts’ Sourcing Decision” SeeSALT Blog Post Author: Nicole Boutros
07/23/19	“The 5 Supermajority Tax Challenges Facing California” Law360 Authors: Robert Merten III and Richard Nielsen
07/02/19	“Defeating a State Tax False Claims Act Case” Law360 Authors: Marc Simonetti and Nicole Boutros
06/21/19	“Gross! Portland, Oregon, Targets Large Retailers with New Gross Receipts Tax” SeeSALT Blog Post Authors: Pillsbury SALT
05/17/19	“The Evolution of Software as a Service Taxes Post-Wayfair” Law360 Authors: Marc Simonetti, Dmitrii Gabrielov and William Bennett
04/25/19	“California Governor Signs Marketplace Facilitator Legislation, Preview to New Rules” Pillsbury Client Alert Authors: Pillsbury SALT
04/16/19	“California Business Tax May Provide High Court Nexus Test” Law360 Authors: Carley Roberts and Mike Le
03/18/19	“Taxpayers Benefit from Courts Declining Agency Deference” Law360 Authors: Carley Roberts and Mike Le
03/18/19	“Commerce Clause Decisions Open Door for TCJA-Related Challenges” State Tax Notes, Vol. 91, No. 11 Authors: Evan Hamme and Timothy Gustafson
02/09/19	“The Upland Ripple Effect: A California Supermajority Tax Showdown” Law360 Authors: Robert Merten III and Richard Nielsen
01/15/19	“Transparency Versus Confidentiality in 2019 Tax Disputes” Law360 Authors: Pillsbury SALT
01/01/19	“Revisiting California Tax Residency after the TCJA” Journal of Multistate Taxation and Incentives, Vol. 28, No. 9 Authors: Mike Le and Eric Coffill
12/03/18	“SeeSALT Digest – The Exhaustion Doctrine and De Novo Review” State Tax Notes Authors: Carley Roberts and Jessica Allen
08/24/18	“Local Sugar Taxes May Be Headed for a Crash” Law360 Authors: Jessica Allen and Carley Roberts
07/24/18	“Captive Audience: More States Instruct Taxpayers to Include Captive Insurance Companies in Combined Returns” Bloomberg’s Daily Tax Report: State Authors: Dmitrii Gabrielov and Andrew Appleby
06/20/18	“Fund Managers Face Tax Hike If California Passes AB 2731” Law360 Authors: Pillsbury SALT
03/26/18	“Implications of the MTC’s Market-Based Sourcing Model Regulations” State Tax Notes Authors: Robert Merten III, Jeffrey Friedman, and Nicholas Kump
03/22/18	“California’s Clean Energy Equipment Tax Exemption and the Value of Stakeholder Input” Law360 Authors: Carley Roberts, Robert Merten III and Jessica Allen
12/31/17	“California Supreme Court Expands the California Real Estate Transfer Tax to Entity Transfers that Cause Property Tax Re-Assessments under Proposition 13” AFIRE News Authors: Craig A. Becker, Richard E. Nielsen, Breann E. Robowski and Andrew J. Weiner
10/10/17	“How States Are Trying New Strategies To Collect Sales Tax” Law360 Authors: Pillsbury SALT
10/06/17	“Many Questions Unanswered After California’s Tax Shakeup” Law360 Authors: Pillsbury SALT
09/07/17	“Blazing a Trail for More Local Taxes by Ballot Initiative” Law360 Authors: Pillsbury SALT
07/07/17	“Imposing Documentary Transfer Taxes in California After Ardmore” Law360 Authors: Pillsbury SALT
07/01/17	“Some Observations on Gross Receipts Taxes” Journal of Multistate Taxation and Incentives Author: Jessica N. Allen
06/12/17	“Taxes, Fees and “Something Else”: California’s Morning Star Decision” State Tax Notes Authors: Robert P. Merten III and Eric J. Coffill
01/01/17	“Nortel, Lucent and Taxing Embedded Software in California Under a Technology Transfer Agreement” Journal of Multistate Taxation and Incentives Authors: Pillsbury SALT
08/31/16	“Quick Points – Property Taxation and Software in California” California Tax Lawyer, Vol. 25, No. 4 Author: Breann E. Robowski
03/17/16	“New York Untangles Unauthorized Insurance Co. Taxation” Law360 Authors: Pillsbury SALT
09/21/15	“How to Defend a Remote Access to Software Sales Tax Audit, Part II” State Tax Notes Authors: Evan M. Hamme and Leah Robinson
07/13/15	“Hyatt to Make Second Trip to the United States Supreme Court in Continuing Battle with the Franchise Tax Board” Law360 Authors: Pillsbury SALT
02/09/15	“Six New York Tax Reform Decisions to Make in 2015” State Tax Notes Authors: Pillsbury SALT
09/29/14	“What New York Can Learn From California’s Combined Reporting History” State Tax Notes Authors: Carley A. Roberts, Pilar Mata, Stephanie T. Do, and Kathryn E. Pittman
05/19/14	“Heads They Win, Tails You Lose: New York Decombination and Discretionary Adjustments” State Tax Notes Authors: Pillsbury SALT
07/01/13	“What’s Left of the Equal Protection Clause?” IPT Tax Report Author: Zachary T. Atkins
12/10/12	“A Pinch of Salt: The Deliberative Process Privilege in State Controversy Matters” Tax Notes State Authors: Marc A. Simonetti and Zachary T. Atkins
10/01/12	“Between a Rock and a Hard Place: Third-Party Enforcement Actions” Tax Anlysts Authors: Carley Roberts, Tim Gustafson, and Jack Trachtenberg
08/06/12	“Intrastate Apportionment: Ripe for Equitable Relief?” Tax Analysts Authors: Carley A. Roberts, Prentiss Willson, and Maria M. Todorova
11/01/11	“An Overview of California’s 2004 Tax Amnesty Legislation” The Tax Executive Authors: Pillsbury SALT
08/01/11	“Storm Shelter: California’s New Voluntary Compliance Initiative” Tax Analysts Authors: Carley A. Roberts and Timothy A. Gustafson
08/01/11	“Setting the Record Straight — Evidentiary Pitfalls in SALT Litigation” Tax Notes State Author: Zachary T. Atkins, Eric S. Tresh, Maria M. Todrova, Stephen P. Kranz
04/11/11	“Auditors Must Not Use Jeopardy Assessments to Coerce Taxpayers” Tax Notes State Author: Marc A. Simonetti, Zachary T. Atkins, Madison J. Barnett
08/01/07	“California FTB Offers 60-Day Period for Taxpayers to Complete Reportable Transaction Disclosure Statements in Order to Avoid Penalties” Practical U.S./Domestic Tax Strategies Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Sections 19331 and 19385: When Can a Taxpayer Consider a Claim for Refund Deemed Denied?” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 19322.1: Informal Claims for Refund” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 19322: Filing a Valid Claim for Refund” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 19308: Filing a Claim for Refund Beyond the Normal Time Periods in Section 19306” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 19164: Defending Against the Accuracy-Related and Fraud Penalties” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 19043.5: Notice of Proposed Adjusted Carryover Amount” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 17951: California Source Income and Its Many Quandaries” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 17016: No Presumption of Nonresidence When the Taxpayer Spends Less Than Nine Months in California” Lexis California Tax Practice Insights Authors: Pillsbury SALT
06/01/06	“California Revenue & Taxation Code Section 17014 and Title 18, California Code of Regulations Section 17014: Intent Not Enough to Establish Residency” Lexis California Tax Practice Insights Authors: Pillsbury SALT
11/28/05	“California Revenue & Taxation Code Section 24425: Disallowance of Interest Expense Deductions” Lexis California Tax Practice Insights Authors: Pillsbury SALT
01/01/05	“California 2004 State and Local Tax: Important Developments” State and Local Tax Lawyer Authors: Pillsbury SALT
11/01/04	“An Overview of California’s 2004 Tax Amnesty Legislation” The Tax Executive Authors: Pillsbury SALT
08/23/04	“California Enacts New FTB and BOE Penalties Affecting Pending Audits, Protests, Appeals and Settlements” Tax Analysts Authors: Carley A. Roberts and Eric J. Coffill
01/01/04	“California 2003 State and Local Tax: Important Developments” State and Local Tax Lawyer Author: Carley Roberts
01/01/03	“California 2002 State and Local Tax: Important Developments” State and Local Tax Lawyer Author: Carley Roberts
01/01/02	“California 2001 State and Local Tax: Important Developments” State and Local Tax Lawyer Authors: Pillsbury SALT
09/24/01	“A Status Report on the California FTB’s Proposed Audit Regulation” Tax Analysts Authors: Carley A. Roberts and Eric J. Coffill
07/01/01	“California Assembly Bill Proposes Expanded Sales/Use Tax Nexus Rules Affecting Internet Sellers” Cyberspace Lawyer Authors: Pillsbury SALT
01/01/00	“California 1999 State and Local Tax: Important Developments” State and Local Tax Lawyer Authors: Pillsbury SALT