Evan M. Hamme

Evan has extensive experience helping clients understand and navigate through the state and local tax consequences of corporate structures and transactions. Evan advises on state and local conformity to federal income tax calculation rules, as well as the tax impact of corporate income tax formulary apportionment rules. Evan has advised clients in planning matters and successfully defended such advice through subsequent audit and litigation. Evan’s broad experience provides him with the perspective needed to aid clients with tax issues at any stage and in any forum. Prior to joining Pillsbury, Evan practiced state and local tax as an associate at a major law firm in New York City.

• Advised major retail company on restructuring transactions and successfully defended such advice in multiple audits and administrative proceedings.

• “‘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.
• “Texas Court of Appeals Confirms Cost-of-Performance Method Is Proper to Source Service Receipts,” SeeSALT, November 28, 2022. Coauthor.
• “Maryland Court Invalidates Maryland’s First-of-Its-Kind Digital Ad Tax,” SeeSALT, October 21, 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.
• “Pennsylvania Legislation Provides Updates to Corporate Income Tax Law,” SeeSALT, August 30, 2022. Coauthor.
• “New Jersey Supreme Court Requires Factual Record in Jersey City Payroll Tax Dispute,” SeeSALT, July 21, 2022. Coauthor.
• “New Tax Legislation Shifts Consolidated Return Landscape in Georgia,” client alert, May 11, 2022. Coauthor.
• “Texas Supreme Court Sides with Sirius XM’s ‘Straightforward’ Interpretation of Service Receipt Sourcing Statute,” SeeSALT, March 29, 2022. Coauthor.
• “U.S. Solicitor General Recommends the Supreme Court Decline New Hampshire v. Massachusetts,” SeeSALT, June 7, 2021. Coauthor.
• “New York Budget Raises Tax Rates, Provides Relief to Address Pandemic,” client alert, April 15, 2021. Coauthor.
• “Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on ‘Convenience of the Employer’ Rule,” February 11, 2021.
• “Pennsylvania’s Agency Deference Bait and Switch: Synthes USA,” Tax Notes State, August 26, 2020. Coauthor.
• “New Mexico Court of Appeals Upholds Refund Claim Dismissal for Taxpayer’s Violation of Discovery Order,” SeeSALT, March 6, 2020.
• “‘Interactive’ Website Will Defeat P.L. 86-272 Immunity If the MTC Has Its Way,” SeeSALT, with Pillsbury SALT, November 11, 2019.
• “The California Franchise Tax Board Convenes a Public Meeting on the Gig Economy,” SeeSALT, with Pillsbury SALT, October 2, 2019.
• “California OTA Rejects FTB’s 0.2 Percent Bright-Line Nexus Standard for Out-Of-State Minority Interest LLC Members,” SeeSALT, with Pillsbury SALT, September 9, 2019.
• “Gross! Portland, Oregon, Targets Large Retailers with New Gross Receipts Tax,” SeeSALT, with Pillsbury SALT, June 21, 2019.
• “California Governor Signs Marketplace Facilitator Legislation, Preview to New Rules,” client alert, with Pillsbury SALT, April 25, 2019.
• “Commerce Clause Decisions Open Door For TCJA-Related Challenges,” State Tax Notes, March 18, 2019.
• “How to Defend a Remote Access To Software Sales Tax Audit, Part II,” State Tax Notes, September 21, 2015.
• “How to Defend a Remote Access To Software Sales Tax Audit, Part I,” State Tax Notes, July 27, 2015.
• Speaking Engagements

  • Single Sales Factor: Simplicity or Distortion? The Fair Apportionment Debate,” COST SALT in a Digital World Workshop, March 2026, Burlingame, Calif.

  • “One Big Beautiful Bill Act (OBBBA) and its Impact on State Corporate Income Taxes,” COST Annual Meeting, September 2025, Memphis, Tenn.

  • “Sourcing Issues for Income Tax,” COST SALT Workshop for Technology Companies, August 2025, Burlingame, Calif.
  • “Return Filing Methods,” COST Intermediate/Advanced State Income Tax School, May 2025, Dallas, Tex.
  • “Apportionment of Foreign Source Income,” COST Spring Meeting, April 2025, New Orleans, LA.
  • “Discussion of State Tax Cases, Issues & Policy Matters to Watch,” COST Pacific Northwest Regional State Tax Seminar, December 2024, Redmond, Wash.
  • “Pillar Two Shakes Up SALT: Strategies for the New Landscape,” 2024 TEI Annual Meeting, October 2024, San Antonio, Tex.
  • “The Impact of Loper Bright on State Tax Authority and Taxpayer Deference,” COST Annual Meeting, September 2023, St. Louis, Mo.
  • “Digital Assets: The Continuing Impact of the TCJA on State Income Taxation,” COST SALT Workshop for Technology Companies, August 2024, Cupertino, Calif.
  • “Filing Methodologies,” COST Advance Income Tax School, May 2024, Atlanta, Ga.
  • “Border Crossings: State Tax Complexities for Multinational Businesses,” COST Spring Conference & Audit Sessions, April 2024, Boston, Mass.
  • “Another Year of Change – State (and Federal/International) Tax Reform,” Practising Law Institute Hot Topics in State & Local Tax, March 2024, New York, N.Y.
  • “Defending Your Position: Best Practices for Handling Indirect Tax Appeals/Disputes,” COST State Indirect Tax Seminar, December 2023, Atlanta, Ga.
  • “Intercompany Transactions & Transfer Pricing,” Paul J. Hartman SALT Forum, October 2023, Nashville, Tenn.
  • “On What Basis? Identifying and Calculating Tax Base Differences Between Federal and State Asset Basis,” COST Annual Meeting, October 2023, Las Vegas, Nev.
  • “Filing Methodologies,” COST Advanced Income Tax School, May 2023, Dallas, Tex.
  • “SALT West Coast Developments – California, Oregon, Washington, New Mexico,” TEI New York Chapter Meeting, April 2023, New York, N.Y.
  • “How to do SALT in 2022 and Beyond,” 2022 COST Annual Meeting, October 2022, Orlando, Fla.
  • “State Tax Cases, Issues & Policy Matters to Watch in 2022 and Beyond,” COST Southeast Regional State Tax Seminar/Healthcare Indirect Tax Seminar, August 2022, Nashville, Tenn.
  • “Hot Topics in Indirect Tax with a Focus on Healthcare,” COST Southeast Regional State Tax Seminar/Healthcare Indirect Tax Seminar, August 2022, Nashville, Tenn.
  • “Filing Methodologies,” COST Advanced Income Tax School, May 2022, Atlanta, Ga.
  • “Tax Implications of COVID-19: Nexus and Other Considerations of the New Remote Workforce,” TEI Carolinas, November 2021, Webinar.
  • “SALT Implications of the CARES Act and Other Recent State Tax TCJA Developments,” TEI Chicago Chapter SALT Program, December 2020, Webinar.
  • “SALT Implications of the CARES Act and Other Recent State Tax TCJA Developments,” TEI Chicago Chapter SALT Program, December 2020, Webinar.
  • “SALT Cross Pollination: U.S. and international approaches to taxing foreign source income,” TEI Silicon Valley Chapter’s SALT Day & IPT Joint Meeting, December 2019. Santa Clara, Calif.
  • “Treatment of Income from Foreign Affiliates after Tax Reform,” Strafford Tax Law Webinar. July 2019.
• Honors & Awards
  • Recognized by Best Lawyers: Ones to Watch (published by BL Rankings LLC) Tax Law (2026).
  • Recognized by Lawdragon as one of 500 Leading Global Tax Lawyers (2025).
• Press Mentions
  • “Transfer Pricing Relevant for Addback Exceptions, Panel Says,” Tax Notes State, October 26, 2023.
  • “States Should Consider Bilateral Pricing Programs, Atty Says,” Law360, October 24, 2023.
  • “Telework Nexus Burdens Grow As States Shed Pandemic Relief,” Law360, July 30, 2021.