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SeeSALT Blog — Published by StateLocal Tax Attorneys Pillsbury Winthrop Shaw Pittman LLP SeeSALT Blog Published By Pillsbury Winthrop Shaw Pittman LLP. Navigation Home Events Publications ContactSearch on SeeSALT Blog Search Insights on the U.S. state and local tax landscape Proposed Initiative to Amend San Francisco Business Taxes Posted May 9, 2024 by Jeffrey M. Vesely and Richard E. Nielsen Jeffrey M. Vesely Richard E. Nielsen A proposed initiative ( available here ) is being circulated to place on the November 5, 2024 ballot, an ordinance amending the Business and Tax Regulations Code effective January 1, 2025. Continue Reading › Print by Jeffrey M. Vesely and Richard E. Nielsen Posted in: California Posted May 9, 2024 Updated: May 9, 2024 5:59 pm New Jersey Issues Guidance on Adoption of Federal Partnership Audit Regime Posted May 6, 2024 by Taylor A.F. Wolff and Robert P. Merten III Taylor A.F. Wolff Robert P. Merten III On April 5, 2024, the New Jersey Division of Taxation issued guidance discussing New Jersey’s adoption of the federal centralized partnership audit regime enacted as part of the federal Bipartisan Budget Act of 2015, P.L. 114-74. The guidance was released over a year after the Senate and General Assembly of the State of New Jersey approved P.L. 2022, c. 133 on December 22, 2022. This law applies to any adjustments to a taxpayer’s federal taxable income on or after January 1, 2020. Continue Reading › Print by Taylor A.F. Wolff and Robert P. Merten III Posted in: New Jersey Posted May 6, 2024 Updated: May 6, 2024 5:31 pm South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department Posted April 22, 2024 by Breanna N. Zagorski and Zachary T. Atkins Breanna N. Zagorski Zachary T. Atkins 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 new standards, enacted as part of Senate Bill 298 , are expected to rein in the Department’s aggressive use of forced combination, which has led to considerable tax controversy in the state. Continue Reading › Print by Breanna N. Zagorski and Zachary T. Atkins Posted in: South Carolina Posted April 22, 2024 Updated: April 26, 2024 4:06 pm Reminder: Gross” Does Not Mean Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor Posted April 4, 2024 by Carley Roberts , Robert P. Merten III , Jeff Phang and Nolan Kessler Carley Roberts Robert P. Merten III Jeff Phang Nolan Kessler In a decision marked not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator. First, the OTA rejected the matching principle” included in FTB Ruling 2006-01, and supported its holding based primarily on the plain language of Cal. Rev.Tax. Code § 25120(f)(2), and legislative history. Second, the OTA rejected the FTB’s argument that repatriated dividends constitute a substantial and occasional sale of property under FTB Regulation 25137(c)(1)(A). Last, the OTA determined the FTB failed to carry its burden to show the taxpayer’s inclusion of 100 percent of repatriated dividends in the sales factor denominator is distortive under Cal. Rev.Tax. Code § 25137. Anyone may submit a request to the OTA requesting the decision be marked precedential.” The California Office of Tax Appeals (OTA), in a decision marked not precedential” in the Matter of the Appeal of Microsoft CorporationSubsidiaries , held 100 percent of repatriated dividends under the Tax Cuts and Jobs Act (TCJA) must be included in the taxpayer’s sales factor denominator. Continue Reading › Print by Carley Roberts , Robert P. Merten III , Jeff Phang and Nolan Kessler Posted in: Apportionment Posted April 4, 2024 Updated: April 4, 2024 1:58 pm COST’s 2024 Spring Conference Posted March 25, 2024 by Pillsbury SALT Pillsbury SALT SALT partners Zachary Atkins and Evan Hamme will speak at COST’s upcoming Spring Conference. Continue Reading › Print by Pillsbury SALT Posted in: Apportionment Posted March 25, 2024 Updated: March 25, 2024 7:32 pm Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes Posted March 20, 2024 by Jeff Phang , Robert P. Merten III and Carley Roberts Jeff Phang Robert P. Merten III Carley Roberts The California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA) and California Employment Development Department (EDD) announced tax relief for certain California counties affected by severe winter storms. Continue Reading › Print by Jeff Phang , Robert P. Merten III and Carley Roberts Posted in: California Posted March 20, 2024 Updated: March 20, 2024 7:34 pm Got Remote Workers? Supreme Court of Ohio Upholds Pandemic Rule for Municipality Tax Posted March 4, 2024 by Taylor A.F. Wolff and Robert P. Merten III Taylor A.F. Wolff Robert P. Merten III The Supreme Court of Ohio has held the Ohio legislature did not violate the Due Process Clause of the U.S. Constitution by directing an Ohio citizen to pay taxes to the municipality where the employee’s principal place of work was located rather than to where the employee actually worked. Continue Reading › Print by Taylor A.F. Wolff and Robert P. Merten III Posted in: Income Tax Posted March 4, 2024 Updated: March 5, 2024 11:32 am TEI’s 2024 Midyear Conference Posted February 16, 2024 by Pillsbury SALT Pillsbury SALT SALT attorney Aruna Chittiappa will speak at TEI’s 2024 Midyear Conference on March 19. Continue Reading › Print by Pillsbury SALT Posted in: Events Posted February 16, 2024 Updated: February 16, 2024 8:03 pm PLI’s Hot Topics in State and Local Tax 2024 Posted February 16, 2024 by Pillsbury SALT Pillsbury SALT SALT partner Evan Hamme will speak at PLI’s Hot Topics in State and Local Tax 2024. Continue Reading › Print by Pillsbury SALT Posted in: Events Posted February 16, 2024 Updated: February 16, 2024 4:46 pm 2024 ABA-IPT Advanced Sales and Use Tax Seminar Posted February 16, 2024 by Pillsbury SALT Pillsbury SALT SALT partner Carley Roberts will moderate a panel at this year’s ABA-IPT Advanced Sales and Use Tax Seminar. Continue Reading › Print by Pillsbury SALT Posted in: Events Posted February 16, 2024 Updated: February 16, 2024 3:28 pm Next PageThe Pillsbury State and Local Tax group provides a multistate perspective on the complex U.S. state and local tax system. Our experience advising and representing clients on income, franchise, sales, use, excise and property tax allows us to see and anticipate the developments and trends in the constantly evolving SALT landscape. 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