Publications


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 ZagorskiZachary 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:  and

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:  and 

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:  and 

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: and

03/18/19 “Taxpayers Benefit from Courts Declining Agency Deference”

Law360
Authors: and

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: and

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:

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:

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. AtkinsEric 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. SimonettiZachary T. AtkinsMadison 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:

01/01/03 “California 2002 State and Local Tax: Important Developments”

State and Local Tax Lawyer
Author:

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