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Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs

The Arizona Court of Appeals held that an investment tax credit (ITC) deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property tax…more

Arizona, Energy Projects, Energy Sector, Energy Storage, Income Taxes

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Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs

The Arizona Court of Appeals held that an investment tax credit (ITC) deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property tax…more

Arizona, Energy Projects, Energy Sector, Energy Storage, Income Taxes

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New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing

The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source…more

Business Taxes, Income Taxes, New Jersey, State and Local Government, Tax Court

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Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business

On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT) including expanding the definition of what constitutes a “unitary business.”  The…more

Business Taxes, Corporate Taxes, New Jersey

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New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the…more

Administrative Law Judge (ALJ), Income Taxes, New York, Partnerships, Tax Liability

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Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator…more

Apportionment, California, Dividends, Income Taxes, Sales Factor

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California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)

Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January…more

California, Corporate Taxes, Inflation Reduction Act (IRA), Internal Revenue Code (IRC), New Legislation

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Technology Transfer Agreements: An Update on Latest Developments in California

The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs)…more

Business Taxes, California, Copyright, Intangible Property, Intellectual Property Protection

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California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)

Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January…more

California, Corporate Taxes, Inflation Reduction Act (IRA), Internal Revenue Code (IRC), New Legislation

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California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)

Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January…more

California, Corporate Taxes, Inflation Reduction Act (IRA), Internal Revenue Code (IRC), New Legislation

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California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (“ACA 11”) which proposes to abolish the State Board of Equalization (“BOE”) and reassign its responsibilities to other state tax agencies…more

Board of Equalization, Constitutional Amendment, Property Tax, Tax Assessment

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California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (“ACA 11”) which proposes to abolish the State Board of Equalization (“BOE”) and reassign its responsibilities to other state tax agencies…more

Board of Equalization, Constitutional Amendment, Property Tax, Tax Assessment

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Technology Transfer Agreements: An Update on Latest Developments in California

The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs)…more

Business Taxes, California, Copyright, Intangible Property, Intellectual Property Protection

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South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department

Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return.  These…more

Apportionment, Corporate Taxes, Income Taxes, New Legislation, State and Local Government

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