Publications


05/17/19 “The Evolution of Software as a Service Taxes Post-Wayfair”

Law360
Authors: , and

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 M. Hamme and Timothy A. Gustafson

02/09/19 “The Upland Ripple Effect: A California Supermajority Tax Showdown”

Law360
Authors: Robert P. Merten III and Richard E. 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 J. 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

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 P. Merten III, Jeffrey A. Friedman, and Nicholas J. Kump

03/22/18 “California’s Clean Energy Equipment Tax Exemption and the Value of Stakeholder Input”

Law360
Authors: Carley Roberts, Robert P. Merten III and Jessica N. 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

12/10/12 “The Deliberative Process Privilege in State Controversy Matters”

State Tax Notes
Author:

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

08/01/07 “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