Blog Post 10.30.25
Breanna Zagorski advises clients on a variety of state and local tax matters, including multistate litigation, planning, audit defense and controversy issues.
Prior to joining Pillsbury, Breanna was an associate at a global accounting firm, where she provided state and local tax due diligence services for proposed real estate merger and acquisition deals. In addition, she advised clients on state and local income tax, franchise tax, and sales and use tax issues.
Professional Highlights
- Breanna received a Clinical Excellence Award and Pro Bono Award upon graduation of law school for her participation in Hofstra Law’s Federal Tax Clinic, where she advised individuals with tax controversy issues.
- Breanna was also the president of Tax Law Society, where she prepared federal and state income tax returns for low-income individuals and families as part of her school’s Volunteer Income Tax Assistance program.
- Breanna served as Articles Editor of the Family Court Review journal.
View More
- Publications
- “South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department,” SeeSALT, April 22, 2024. Coauthor.
- “New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location,” SeeSALT, February 6, 2024. Coauthor.
- “Taxation Without Representation: Michigan Supreme Court Says Neither State Law Nor the U.S. Constitution Requires Inclusion of Receipts From Deemed Asset Sale in Sales Factor,” SeeSALT, August 21, 2023. Coauthor.
- “‘If You Don’t Make It There, You Can’t Make It Anywhere:’ New York’s Zero Manufacturing Rate Requires New York Property,” client alert, April 27, 2023. Coauthor.
- “Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing with Market-Based Sourcing,” SeeSALT, April 25, 2023. Coauthor.
- “Maryland Digital Ad Tax Updates: Comptroller Seeks Stay of State Court Decision Striking Tax and Recently Dismissed Federal Challenge Is Under Appeal,” SeeSALT, January 11, 2023. Coauthor.
- “Primary Function’ Test Propels Yet Another Service Provider to Victory in New York Sales Tax Case,” SeeSALT, October 25, 2022. Coauthor.
- “Everything in Its Place: New Mexico Hearing Officer Finds Markup for Out-of-State Service is Exempt, While Reimbursements for New Mexico Employee Payroll Are Taxable,” SeeSALT, October 18, 2022. Coauthor.
- “Taking the Hit: Despite IRS Attempts, Domestic Abuse Victims Cannot Get Innocent Spouse Protection When Their Partner’s Commit Tax Fraud,” Family Court Review, Volume 59, Issue 3.
- Speaking Engagements
- “Legislation & Regulations,” COST California Corporate Income Tax Webinar, June 2025, Webinar.
- “Major State Tax Trends: Transfer Pricing and Digital Taxation,” COST Pacific Northwest Regional State Tax Seminar, December 2024, Redmond, WA.
Education
-
J.D., Hofstra University School of Law, 2021
B.S.B.A., Finance and International Business, Duquesne University, 2018
Admissions
-
New York