Faith joins Pillsbury’s New York office as a senior law clerk.

5 Questions with Faith

1. Who inspires you?

My family and friends inspire me every day through their hard work, dedication, and everything they have accomplished.

2. What drew you to the law?

I have always enjoyed reading, writing, and finding ways to help people.  I felt like the law would allow me to be involved in all three.

3. What aspect of State and Local Tax law do you find most interesting?

What I find most interesting about state and local tax law is how often it intersects with other areas of law. The constant changes keep the work engaging, and I enjoy the challenge of working through complex issues to find solutions.

4. What is one of your most memorable / funniest / happiest times during law school?

One of the highlights of law school was participating in the school’s legal clinic, where I had the opportunity to work directly with nonprofit clients and help them navigate unique legal issues while still a student.

5. What do you do for fun? Any hidden talents?

For fun I like to read novels and make baked goods for my friends and family!

The post Welcome to Pillsbury SALT, Faith! appeared first on SeeSALT Blog.

The FIT applies to banks and other financial institutions for the privilege of doing business in Ohio.  The tax base is total Ohio equity capital, which a bank calculates by apportioning its total equity capital to Ohio using a gross receipts factor.  After apportionment, the bank applies the following rates: (i) 0.8% on the first $200 million of Ohio equity capital; (ii) 0.4% on Ohio equity capital greater than $200 million and less than $1.3 billion; and (iii) 0.25% on Ohio equity capital of $1.3 billion or more.

Dollar Bank argued that the FIT’s regressive rate structure was internally inconsistent and therefore violated the Commerce Clause as applied.  The internal consistency test “‘looks to the structure of the tax at issue to see whether its identical application by every State in the Union would place interstate commerce at a disadvantage as compared with commerce intrastate.’”  Dollar Bank, FSB v. Harris, Slip Op. No. 2026-Ohio-3069, para. 16 (Ohio Aug. 13, 2026) (quoting Comptroller of Treasury of Md. v. Wynne, 575 U.S. 542, 562 (2015)).  To support its argument that the FIT was internally inconsistent, Dollar Bank calculated that for 2017 it would owe about $5.1 million in the aggregate if every state adopted the FIT and about $4.2 million if it conducted the same business entirely in Ohio.

The Ohio Supreme Court nevertheless upheld the FIT.  Explaining that “the primary concern of the internal-consistency test is rooting out state policies that either discriminate against interstate commerce or result in double taxation,” id., para. 17, the court concluded that the FIT did neither.  It observed that if every state adopted the FIT, each would tax only the portion of equity capital apportioned to it, with all apportionment percentages totaling 100 percent.  And because in-state banks and out-of-state banks with the same amount of Ohio equity capital pay the same amount of Ohio tax, the court concluded that the FIT was nondiscriminatory.

Dollar Bank’s higher aggregate tax burden relative to that of a hypothetical, purely intrastate business did not change the court’s analysis.  The court rejected the bank’s comparison of aggregate tax burdens, stating that the U.S. Supreme Court had never applied the internal consistency test in that manner.  The disparity Dollar Bank had identified was attributable to the FIT’s regressive rate structure, a scheme that, as the court put it, “simply favors banks that do more business in Ohio.”  Id., para. 33.  According to the court, because any regressive tax structure could produce such a disparity, “[t]o accept Dollar Bank’s argument would require us to conclude that the Commerce Clause forbids all regressive tax structures,” which the court declined to do.  Id., para. 35.

The case is Dollar Bank, FSB v. Harris, Slip Op. No. 2026-Ohio-3069 (Ohio Aug. 13, 2026), which is available at www.supremecourt.ohio.gov/rod/docs/pdf/0/2026/2026-Ohio-3069.pdf

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Amanda advises clients on a variety of state and local taxation issues with a primary focus on property tax.

She joins Pillsbury’s San Francisco office as a senior associate.

5 Questions with Amanda

1. What first sparked your interest in State and Local Tax?

I’ve always liked math, and state and local tax gives me the opportunity to combine it with reading and legal analysis. I especially enjoy working through a valuation where the facts, the numbers, and the law all matter.

2. What drew you to the law?

My dad is a real estate attorney. I have early memories of the stacks of papers in his office, but also of his ability to solve real-world problems. My mother deserves some credit, too: she says she raised my brother and me to always have opinions, so perhaps it was inevitable that we both became lawyers.

3. What aspect of State and Local Tax law do you find most interesting?

State and local taxes influence how businesses operate and make decisions. The longer I practice, the more interesting I find that connection. I also appreciate that, through litigation, we can help shape how the law is applied.

4. What is your go-to comfort food?

A steak or ribs when I’m back in the Midwest.

5. What do you do for fun?

I really enjoy walks outside, yoga sculpt class, taking long hikes, and watching sports.  I am happiest in warm weather.

The post Welcome to Pillsbury SALT, Amanda! appeared first on SeeSALT Blog.

Zack is presenting on the topic “All About the Acronyms: State Taxation of Foreign-Source Income.” Foreign-source income can produce very different results for state tax purposes than it does federally. This session will provide a practical framework for analyzing the constitutional, conformity, income inclusion, deduction, apportionment and reporting issues that are created when states seek to tax foreign income.

Aruna will speak on the topic “When the Formula Fails: Mismatched Metrics, Distorted Results and Constitutional Limits on State Taxation.” As states and local jurisdictions continue to modernize apportionment rules, taxpayers increasingly face situations where the metrics used to source income bear little relationship to actual economic activity. The result can be double taxation, nowhere income or significant distortions that raise constitutional concerns. This session will explore the growing tension between state sourcing regimes and constitutional apportionment principles, highlighting emerging controversies, litigation trends and practical strategies for addressing inequitable outcomes.

The Professor Paul J. Hartman State and Local Tax Forum provides industry, practitioners and state revenue employees the opportunity to participate in a quality forum exploring significant national developments and trends in state and local taxation. The Forum features speakers with the knowledge, expertise and communication skills to impart current developments as well as the practical solutions and planning opportunities in structuring and reporting state and local tax transactions.

For more information or to register, please visit the event page.

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The post 2026 TEI Annual Conference appeared first on SeeSALT Blog.

Join Annie and Carley for this two-and-a-half-day conference—the premier California educational and networking event for tax practitioners nationwide, including attorneys, accountants, corporate tax executives, financial planners, enrolled agents, state and federal government officials, and tax professionals of all levels of experience.

On Thursday, October 1, 2026, from 8:30 am to 9:20 am, Annie Rothschild will participate in the panel, “Return of the 3-Factor Formula?: Apportionment Updates.” The panelists will discuss developments related to California’s apportionment and alternative apportionment systems and examine the recent Smithfield decision and its potential impacts, special industry apportionment regulations, and the move to single-sales factor apportionment for banks and financial corporations.

Carley Roberts will join the “SALT Litigation Update” panel session on Thursday, October 1, 2026, from 9:30 am to 10:20 am. The panelists will provide an overview of major tax legislation enacted in California in 2026, including updates affecting income, sales and use, property, and excise taxes, and highlight significant statutory changes and emerging trends, and their practical implications for taxpayers and practitioners.

For more information or to register, please visit the California Lawyers Association event page.

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Zachary Atkins: State Efforts to Broaden the Sales Tax Base: Legislative Trends and Administrative Actions

Wednesday, September 23, 2026, 2:15pm – 3:10pm

Carley Roberts: Dividing the Pie: Apportionment Challenges from Smithfield, Florida v. California and Others

Thursday, September 24, 2026, 9:05am – 100:00am

Evan Hamme: Economic Substance and Business Purpose Doctrines in State Taxation

Thursday, September 24, 2026, 1:40pm – 2:35pm

This three and a half day Annual Meeting offers sessions for every state tax and government affairs professional with tax responsibilities. The meeting has an extensive program covering all types of state and local taxes that business taxpayers are confronted with on a daily basis.

For more information and to register, please visit the event page.

The post COST’s 57th Annual Meeting appeared first on SeeSALT Blog.

• Craig Becker, Palo Alto
  • Litigation and Controversy – Tax
  • Tax Law
• Breann Robowski, Palo Alto
  • Litigation and Controversy – Tax
• Carley Roberts, Sacramento
  • Litigation and Controversy – Tax
  • Tax Law
• Jeffrey Vesely, San Francisco
  • Litigation and Controversy – Tax
  • Tax Law

This recognition reflects the continued strength of Pillsbury’s SALT practice and its depth of experience advising clients on complex state and local tax matters, including tax controversy, litigation, audits, administrative proceedings and strategic tax planning.

Best Lawyers is a peer review publication that recognizes attorneys for professional excellence in their respective practice areas. The inclusion of multiple SALT team members across California underscores the group’s broad capabilities and reputation in both controversy and transactional tax matters.

Congratulations to Craig, Breann, Carley and Jeffrey on this well-deserved recognition.

The post Pillsbury’s SALT Team Recognized in Best Lawyers appeared first on SeeSALT Blog.

Zachary Atkins and Jeff Phang: California SALT Updates
August 11, 2026, 2:10pm – 3:10pm ET

Aruna Chittiappa and Nolan Kessler: Washington & Utah SALT Updates
August 11, 2026, 3:15pm – 4:00pm ET

Evan Hamme and Breanna Zagorski: Other Western States SALT Updates (including CO, NM & OR)
August 11, 2026, 4:05pm – 4:50pm ET

This live webinar will cover state and local tax issues in the Western States, both legislation and litigation.

For more information or to register, please visit the event page.

The post COST Western States Regional SALT Webinar appeared first on SeeSALT Blog.

This one-hour webinar will cover aspects of state and multistate tax policy that governs state tax systems and reform. It will also address the rationale for state and local taxes and the factors that may affect what types of taxes may be imposed, state interaction with federal rules and taxes, state efforts to achieve uniform rules for multistate income, tax policies in apportioning multistate income, examples of policies shaping California taxes and the basics of the California legislative process.

For more information or to register, please visit the event page.

The post California Lawyers Association Women-in-Tax Committee’s Multistate Tax Policy 101 Webinar appeared first on SeeSALT Blog.