The post New York Imposes Shareholder-Level Tax on Corporate Asset Sale appeared first on SeeSALT Blog.

Evan Hamme – The Evolving Landscape of SALT Litigation and Legislation – Key Issues and Insights
Tuesday, April 21
This opening session will provide a discussion of the significant issues and trends that are emerging from current SALT litigation and legislative matters. This session will cover all SALT tax types and will cue everyone in on the trends in this field.

Aruna Chittiappa – When One Size Doesn’t Fit All: The Limitations of the Single Sales Factor
Tuesday, April 21
The single sales factor apportionment method has become the rule not the exception. This method raises significant questions about fairness, distortion and unconstitutional consequences. The challenges increase when combined with the complexities of taxing foreign source income. This session will discuss how to address the limitations of the single sales factor method.

This Conference will feature presentations on the most recent income and sales tax developments, initiatives and case law updates, and include breakout sessions that will provide in-depth discussions of specific topics for maximum coverage of the hottest income and sales tax issues.

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

The post 2026 COST Spring Conference appeared first on SeeSALT Blog.

The proposed constitutional amendment is intended to curtail local taxes by:

• Reinstating a two-thirds voter approval requirement for all local special taxes, including those placed on the ballot through the citizen initiative process. This is in response to court rulings that allowed citizen-initiated special taxes to pass with a simple majority following California Cannabis Coalition v. City of Upland.
• Restoring the traditional statewide cap on local real estate transfer taxes at $1.10 per $1,000 of property value and repealing local transfer taxes that exceed the cap within two years, including measures like Los Angeles’s Measure ULA.  If passed as written, the amendment would also prohibit charter cities from adopting transfer taxes above that cap.

Supporters argue the measure would restore taxpayer safeguards and voter control over local taxation, while opponents contend it would constrain local government revenues and significantly reduce local tax receipts annually.

The post California Groups File Signatures for Initiative to Curtail Local Taxes appeared first on SeeSALT Blog.

Jack and his fellow panelists will be speaking on the topic “The Invisible Customer: Navigating State Look-Through Sourcing.” TEI’s Midyear Conference, running from March 15-18, 2026, is the premier event for in-house tax professionals to stay ahead by addressing the policy, technology, and practical challenges shaping today’s corporate tax function.

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

The post TEI’s 2026 Midyear Conference appeared first on SeeSALT Blog.

1. VVF Intervest: Rejection of the Continuous Delivery Theory

VVF contract-manufactured products in Kansas for its customer, High Ridge Brands (HRB). At its Kansas manufacturing facility, VVF loaded the finished products onto trucks, arranged by HRB, which were then transported to a third-party distribution center in Columbus, Ohio. The products were warehoused there until they were ordered by HRB’s national retailer customers. At that point, the products were transported by third-party carriers (again arranged by HRB) to the customers’ locations. Approximately 97% of the warehoused products were ultimately transported outside Ohio.

VVF argued that its receipts from sales of products to HRB that were ultimately transported outside Ohio should not be sitused to Ohio, because the Columbus distribution center was merely an interim stop in a continuous delivery process that ultimately ended outside the state. The Board of Tax Appeals agreed with VVF, concluding that Ohio was just one leg in a single transportation chain for purposes of Ohio Revised Code (R.C.) section 5751.033(E). This section provides in relevant part that (i) gross receipts from the sale of tangible personal property are sitused to Ohio if the property is received there by the purchaser, and (ii) when tangible personal property is delivered by motor carrier or other means of transportation, the place at which the property is ultimately received after all transportation has been completed is considered the place where the purchaser receives the property. To the Board, the receipts associated with products that were ultimately shipped from the warehouse to destinations outside Ohio could not be taxed by Ohio.

But the Board’s ruling proved to be only an interim stop in the dispute. On appeal, the Ohio Supreme Court rejected the “continuous delivery theory,” emphasizing that the statute focuses on where the purchaser receives the property from the seller, not on where the property ultimately ends up after subsequent resales by the purchaser. The court held that HRB, as the purchaser, received VVF’s products in Ohio when they arrived at the Columbus distribution center. What HRB did with the products afterward (i.e., reselling and shipping them to retailers outside Ohio), the court explained, was a separate transaction and inconsequential for purposes of situsing VVF’s receipts. Once HRB received the goods in Ohio and took control over storage and later shipments, Ohio became the situs of VVF’s receipts.

2. Jones Apparel Group/Nine West: No Contemporaneous Knowledge Requirement, but Proof Still Required

Only weeks later, the court addressed a different distribution-center scenario in Jones Apparel Group/Nine West Holdings v. Harris. Jones Apparel sold merchandise to DSW, which shipped all such merchandise to its distribution center in Columbus, Ohio, before redistributing it to its retail stores nationwide. Unlike in VVF Intervest, there was no intervening resale by the purchaser. On the basis of later-obtained evidence, Jones Apparel maintained that receipts attributable to sales of merchandise that DSW ultimately transported to its retail stores outside Ohio could not be sitused to Ohio under the CAT.

The case initially appeared to break in the taxpayer’s favor. The Ohio Supreme Court rejected the Tax Commissioner’s view that CAT situsing turns on the seller’s contemporaneous knowledge—at the time of the sale—of the goods’ ultimate destination. The Commissioner had seized upon Jones Apparel’s shipping labels and bills of lading reflecting delivery to Ohio, as well as the taxpayer’s apparent lack of awareness, at the time those documents were created, of whether the merchandise would later be delivered outside the state. Instead, the court held that the Commissioner’s argument “fail[ed] for a simple reason: The contemporaneous-knowledge requirement she claim[ed] to exist in R.C. 5751.033(E) is not there.” Accepting the Commissioner’s position, the court explained, would mean reading a requirement into the statute that the General Assembly did not enact.

But ultimately, the court affirmed the denial of the refund sought by Jones Apparel on evidentiary grounds. The court found that the company had failed to provide documentary evidence quantifying the amount of the refund it sought, i.e., the actual gross receipts attributable to merchandise ultimately received outside Ohio, as required by the refund procedures in R.C. 5751.08(A). The taxpayer’s proffered estimates, data sampled from a limited time period postdating the period at issue, and economic inferences were deemed insufficient.

3. Reading the Cases Together

VVF Intervest underscores that Ohio courts will apply a transaction-by-transaction approach to situsing sales of tangible personal property for CAT purposes, even where evidence shows that the property ultimately comes to rest outside Ohio. Jones Apparel Group/Nine West Holdings, in turn, makes clear that taxpayers seeking refunds on the basis of situsing receipts outside Ohio must precisely quantify such receipts with documentary evidence, rather than estimates, inferences, or limited data samplings. Taxpayers selling to companies that rely on Ohio distribution centers should therefore reassess their CAT exposure and their documentation practices.

The cases are VVF Intervest, L.L.C. v. Harris, Slip Op. No. 2025-Ohio-5680 (Dec. 24, 2025), available at https://www.supremecourt.ohio.gov/rod/docs/pdf/0/2025/2025-Ohio-5680.pdf and Jones Apparel Group/Nine West Holdings v. Harris, Slip Op. No. 2026-Ohio-74 (Jan. 14, 2026), available at https://www.supremecourt.ohio.gov/rod/docs/pdf/0/2026/2026-Ohio-74.pdf.

The post Not the CAT’s Meow: Ohio Supreme Court Reins in the Continuous Delivery Theory for Situsing Receipts appeared first on SeeSALT Blog.

Carley will be speaking on the topic “Factor Fiction: Navigating Denominator Dilemmas.” With many states shifting to a single sales factor to apportion taxable income, determining what is included in the sales factor has become a critical battleground for taxpayers. Among other things, changes by the TCJA (and OBBBA) have caused states to focus on the composition of the sales factor denominator. Recent court decisions and administrative guidance are constantly reshaping which receipts must be included in the “everywhere” denominator, significantly impacting a company’s overall state tax apportionment. This panel will discuss the latest developments, trends and controversies surrounding the sales factor denominator.

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

The post 2026 ABA-IPT Advanced State Income Tax Seminar appeared first on SeeSALT Blog.

Lauren’s experience includes variety of state and local tax matters, including multistate litigation, planning, audit defense and controversy issues.

She joins Pillsbury’s New York office as an associate.

5 Questions with Lauren:

1. Who inspires you?

My family (and my friends that are like family) – I would not be where I am today without their support and words of wisdom along the way.

2. What drew you to the law?

I have always enjoyed research and writing as well as helping people. For me, law was the intersection of those interests.

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

I was actually an English major in college and have always had more of a “right sided” brain. In previous role at KPMG (my first role out of law school), I was introduced to the world of SALT for the first time by incredibly talented mentors who taught and encouraged me to use that side of by brain to think creatively and “outside the box” about SALT law and potential solutions for clients under those laws. I enjoy that the complexities of SALT law allow for that kind of creative thinking in addition to analytical thinking.

4. How do you re-center yourself?

Hanging out with friends and family, particularly down the Jersey Shore during the summer, where my family has had a house since I was born.

5. What is your go-to comfort food? Any interesting facts?

I played rugby in college.

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

SALT attorney Jeff Phang will be presenting at an event hosted by the Sacramento Young Tax Lawyers (SacYTL), in collaboration with the California Lawyers Association – Tax Section.

Join Jeff for an evening of conversation and continuing education focused on mental wellness and sustainability in legal practice.

The evening will begin with a law-school engagement networking mixer, followed by a MCLE panel discussion on the topic “Mental Wellness in Early Legal Practice,” which will explore practical tools and perspectives on managing stress, maintaining mental and physical well-being, and building sustainable professional habits.

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

The post Sacramento Young Tax Lawyers Webinar appeared first on SeeSALT Blog.

Carley Roberts – State Tax Spotlight: Washington and Maryland’s Digital Tax Overhaul
Tuesday, March 3
Two states are leading the charge in redefining how digital transactions are taxed. This session explores Washington’s expansion of sales tax to a wide range of digital and professional services, and will examine Maryland’s new 3% sales tax on digital and IR-related services.

Aruna Chittiappa – The Evolution of Market-Based Sourcing: Navigating the Complexity
Tuesday, March 3
Market-based sourcing has transformed how states apportion corporate income, shifting the focus from where services are performed to where customers receive the benefit. This session explores the evolution of these rules, from early adoption to today’s nuanced frameworks, and examines the challenges posed by technology-driven business models.

Evan Hamme – Single Sales Factor: Simplicity or Distortion? The Fair Apportionment Debate
Tuesday, March 3
The shift to a single sales factor apportionment method has been one of the most significant changes in state corporate income tax policy over the past two decades. This session examines the evolution of single sales factor, its impact on multistate businesses, and the controversies surrounding distortion, internal and external consistency, and alternative apportionment petitions.

Robert P. Merten III – Ask the Experts
Wednesday, March 4
This is your chance to question practitioners and get their views on state and local tax issues related to your technology operations and issues. The panel will answer questions that have been submitted by attendees as well as discussions they’ve had with attendees during the Workshop that would be of interest to other attendees. The panel will also address trends they expect to see in 2026 and beyond, as they apply to the technology industry as well as the use and impact of technology in general.

This workshop will cover the key state and local tax issues that affect everyone using technology in their operations.

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

The post COST’s SALT in a Digital World Workshop appeared first on SeeSALT Blog.

Robert will be speaking on February 23, 2026 on “Legal Ethics.” Craig will be presenting on February 24, 2026 on the topic “California Property Tax and Transfer Tax.”

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

The post CalTax 100th Annual Meeting appeared first on SeeSALT Blog.