Zachary T. Atkins

Before joining Pillsbury, Zack served as the deputy general counsel of a closely held group of companies engaged in manufacturing, retail distribution and e-commerce. Earlier in his career, Zack spent seven years in the state and local tax group of an international law firm, advising Fortune 500 companies and market leaders on multistate tax controversy, planning and policy.

• Publications
  • “California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment,” client alert, February 20, 2025. Coauthor.
  • “A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and Use and District Taxes Paid on Certain ‘Qualified Tangible Personal Property,’” client alert, June 9, 2023. Coauthor.
  • “The Curious First Meeting of the MTC’s Model Receipts Sourcing Regulations Work Group,” client alert, October 18, 2022. Coauthor.
  • “New Tax Legislation Shifts Consolidated Return Landscape in Georgia,” client alert, May 11, 2022. Coauthor.
  • “1^st Amendment Questions After Maryland Billboard Tax Ruling,” Law360, May 21, 2021. Coauthor.
  • “New York Law Authorizing Taxation of Spent Nuclear Fuel Storage Facilities Raises Property Tax Issues for the U.S. Nuclear Industry,” Pratt’s Energy Law Report, May 5, 2021. Coauthor.
  • “Delaware Court Invalidates Division’s NOL Limitation Policy,” Tax Notes State, February 8, 2021. Coauthor.
  • “New York Law Authorizing Taxation of Spent Nuclear Fuel Storage Facilities Raises Property Tax Issues for the U.S. Nuclear Industry,” client alert, January 25, 2021. Coauthor.
  • “Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity,” client alert, January 7, 2021. Coauthor.
  • “What’s Left of the Equal Protection Clause?,” Inst. Prof. Taxation, Tax Report, July 2013.
  • “The Deliberative Process Privilege in State Controversy Matters,” Tax Analysts, State Tax Notes, December 2012. Coauthor.
  • “Setting the Record Straight – Evidentiary Pitfalls in SALT Litigation,” Tax Analysts, State Tax Notes, August 2011. Coauthor.
  • “Auditors Must Not Use Jeopardy Assessments to Coerce Taxpayers,” Tax Analysts, State Tax Notes, April 2011. Coauthor.
• Memberships & Associations
  • Rotary Club of Nashville
  • Nashville Bar Association
  • Member, Tax Law Section, Tennessee Bar Association
  • Member, Taxation Law Section, Georgia Bar Association
  • Member, Tax Section, New York State Bar Association
• Speaking Engagements
  • “State and Local Tax – Swallowing the Whole: Aggressive Taxation of Services,” TEI NY Chapter 62^nd Annual Symposium, November 2025, New York, N.Y.
  • “What Does It Take To Win An Alternative Apportionment Challenge?,” Paul J. Hartman SALT Forum, October 2025, Nashville, Tenn.
  • “Deep Dive into Cost of Performance and Market Based Sourcing: Methods of Multistate Analysis, Planning and Tax Accounts,” COST Annual Meeting, September 2025, Memphis, Tenn.
  • “Litigation,” COST California Corporate Income Tax Webinar, June 2025, Virtual.
  • “Major State Tax Trends: Transfer Pricing and Digital Taxation,” COST Pacific Northwest Regional State Tax Seminar, December 2024, Redmond, Wash.
  • “Sales & Use Tax Developments & Trends,” Paul J. Hartman SALT Forum, October 2024, Nashville, Tenn.
  • “Escalating Burden of Gross Receipts Taxes and Local Taxes (Including Recent SF Activity) on Taxpayers,” COST SALT Workshop for Technology Companies, August 2024, Cupertino, Calif.
  • “Big Gain Hunting,” COST Spring Conference & Audit Sessions, April 2024, Boston, Mass.
  • “Property Tax Litigation and Legislation Issues,” COST State Indirect Tax Seminar, December 2023, Atlanta, Ga. 
  • “Discussion of State Tax Cases, Issues & Policy Matters to Watch,” COST State Indirect Tax Seminar, December 2023, Atlanta, Ga.
  • “State and Local Non-Income Taxes – What You Need to Know Including Franchise Taxes, Gross Receipts and Local Taxes, December 2023, New York, N.Y.
  • “What Exactly Did I Purchase? Applying the True Object and Similar Tests,” Paul J. Hartman SALT Forum, October 2023, Nashville, Tenn.
  • “The Sales Taxation of Digital Products,” COST Annual Meeting, October 2023, Las Vegas, Nev.
  • “Recent Trends in Receipts Factor Sourcing,” SEATA 2023 Annual Conference, July 2023, Little Rock, Ark.
  • “State Tax Legislative & Judicial Updates – National,” CTC/COST Mid-West Regional State Tax Meeting, May 2023, Rolling Meadows, Ill.
  • “SALT Cases Impacting the Landscape – Group Composition, Intercompany Transactions, Sourcing, Alternative Apportionment,” TEI New York Chapter Meeting, April 2023, New York, N.Y.
  • “Market Sourcing and Factor Presence Imposition and Statutes,” Paul J. Hartman SALT Forum, October 2022, Nashville, Tenn.
  • “What’s Hot in State Income Tax,” TEI Fort Worth Chapter Meeting, August 2022, Virtual.
  • “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.
  • “Market-Based Sourcing: Down the Rabbit Hole,” COST Southeast Regional State Tax Seminar/Healthcare Indirect Tax Seminar, August 2022, Nashville, Tenn.
  • “The Incredible, Ever-Expanding Sales Tax Base,” COST Southeast Regional State Tax Seminar/Healthcare Indirect Tax Seminar, August 2022, Nashville, Tenn.
  • “Tax Implications,” Verizon Small Business Accelerator, January 2022, Virtual.
  • “State Income Tax Nexus Issues as a Result of the Pandemic,” TEI Chicago Chapter Virtual State Income Tax Program, December 2021, Webinar.
  • “Tax Implications of COVID-19: Nexus and Other Considerations of the New Remote Workforce,” TEI Carolinas, November 2021, Webinar
  • “Market-Based Sourcing, the Continuing Conundrum,” Paul J. Hartman SALT Forum, October 2021, Nashville, Tenn.
  • “Tax Implications,” Verizon Small Business Accelerator, October 2021, Virtual.
  • “Central or Local Assessment? Tips to Effectively Take Advantage of Either Process,” COST Property Tax Workshop, September 2021, Webinar.
  • “An Update on State and Local Tax Laws – Developments in State and Local Taxation of Communications Companies and Internet Providers,” Federal Communications Bar Association, June 2021, Webinar.
  • “Top 5 Income Tax Trends,” TEI Wisconsin Chapter Meeting, February 2021, Webinar.
  • “Determining the Corporate Income Tax Base,” COST Intermediate/Advanced State Income Tax School, May 2017, Grapevine, Tex,
  • “The Most Important State and Local Tax Litigation,” TEI Columbus/Cincinnati Chapter SALT Day Program, December 2016, Columbus, Ohio.
  • “The Risks of Over Collecting and Under Collecting Sales Tax,” Columbus/Cincinnati Chapter SALT Day Program, December 2016, Columbus, Ohio.
  • “Net Neutrality,” Wichita State University Appraisal for Ad Valorem Taxation Program, July 2016, Wichita, Kan.
  • “State Tax Controversy Updates,” TEI Region VIII Conference, June 2016, Hilton Head, S.C.
  • “A Grand Compromise: The Latest North American Property Tax Developments in Sixty Minutes,” IPT Annual Conference, June 2016, Traverse City, Mich.
  • “State and Local Tax Updates,” Sutherland Tax Education Series, August 2015, Atlanta, Ga.
  • “Southeast Area Property Tax Update,” SEATA Annual Conference, July 2015, Atlanta, Ga.
  • “State Tax Controversy Updates,” TEI Region VII Conference, June 2015, Hilton Head, S.C.
  • “2015 Tax Topics,” NCTA State Leadership Conference, December 2014, Washington, DC.
  • “Current Property Tax Developments,” BTI Annual Conference 2014, October 2014, Half Moon Bay, Calif.
  • “Property Tax 101: Property Tax for the Transaction-Tax Inclined,” IPT 2014 Sales Tax Symposium, September 2014, Washington, DC.
  • “Sales and Use Tax Trends,” CPAacademy.org, August 2014, Webinar.
  • “National Property Tax Developments,” SEATA Annual Conference, July 2014, Point Clear, Ala.
  • “Conformity Issues in State and Local Taxation,” TEI Nashville Chapter Meeting, May 2014, Franklin, Tenn.
  • “Streamlined Sales Tax,” IPT Luncheon, March 2014, Atlanta, Ga.
  • “Property Tax Relief via Incentives and Other Abatement Programs,” COST Property Tax Workshop, January 2014, New Orleans, La.
  • “SALT – Non-Income Tax Update: What You Need to Know Now,” TEI Carolinas Chapter Meeting, October 2013, Charlotte, N.C.
  • “National Update on Transaction Taxes,” IPT Luncheon, May 2012, Atlanta, Ga.
  • “Top 10 Tips for Settling State Audits; When to Waiver or Walk,” TEI Atlanta Chapter Meeting, March 2012, Atlanta, Ga.
  • “Litigation Update,” Wireless Tax Group Conference, January 2012, Kiawah Island, S.C.
• Blog Posts

  • “Not the CAT’s Meow: Ohio Supreme Court Reins in the Continuous Delivery theory for Situsing Receipts,” SeeSALT, February 23, 2026. Coauthor.

  • “No Contract, No Look-Through: Wisconsin Draws a Line on Software Receipts Sourcing,” SeeSALT, January 14, 2026. Coauthor.

  • “California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment,” SeeSALT, February 20, 2025. Coauthor.
  • “Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs,” SeeSALT, September 25, 2024. Coauthor.
  • “New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing,” SeeSALT, July 10, 2024. Coauthor.
  • “South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department,” SeeSALT, April 22, 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.
  • “New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts from ADSL and Fiber Broadband Sales,” SeeSALT. 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.
  • “Texas Comptroller Takes a Serious Look at Sourcing Regulation After SiriusXM Loss,” SeeSALT, January 31, 2023. Coauthor.
  • “Second Place Is Just the First Place Loser: Ohio Supreme Court Rejects State’s Sourcing of NASCAR Intangible Receipts to Ohio,” SeeSALT, November 30, 2022. Coauthor.
  • “’Primary Function’ Test Propels Yet Another Service Provider to Victory in New York Sales Tax Case,” SeeSALT, October 25, 2022. Coauthor.
  • “Broker-Dealer Successfully Fights Look-Through Sourcing in New York,” SeeSALT, May 9, 2022. Coauthor.
  • “Trade Groups Ask SCOTUS to Hear Commerce Clause Challenge to Washington B&O Surtax on Financial Institutions,” SeeSALT, February 9, 2022. Coauthor.
  • “Washington Supreme Court Upholds B&O Surtax on Financial Institutions,” SeeSALT, October 14, 2021. Coauthor.
  • “Massachusetts High Court Approves of Apportionment of Sales Tax on Software Through General Abatement Process,” SeeSALT, June 28, 2021. Coauthor.
  • “Tennessee Creates New Tax Benefits for the Film and Television Industry,” SeeSALT, April 15, 2021. Coauthor.
  • “Maryland Court of Appeals Rejects First Amendment Challenge to Local Tax on Outdoor Advertising Services,” SeeSALT, April 8, 2021. Coauthor.
  • “Oregon Tax Court Rejects Department’s Attempt to Ignore Measure 50 Limitation,” SeeSALT, March 29, 2021. Coauthor.
  • “Indiana Municipalities’ Franchise Fee Lawsuit Against Online Video Providers Remanded to State Court,” SeeSALT, November 23, 2020. Coauthor.
  • “Washington Supreme Court Asked to Review and Overturn Lower Court Decision Invalidating B&O Surtax on Large Financial Institutions,” SeeSALT, October 26, 2020. Coauthor.
  • “New York Trial Court Finds State’s Attempt to Tax Storage Services Performed Entirely in New Jersey Arbitrary and Capricious,” SeeSALT, August 24, 2020. Coauthor.
  • “Appellate Court Says DREs Are Regarded for Tennessee Excise Tax Purposes When Owned by Noncorporate Parent; in Related News, S Corporations Rejoice,” SeeSALT, June 9, 2020. Coauthor.
  • “South Carolina Property Tax Law Discriminates Against Railroads in Violation of 4R Act,” SeeSALT, May 27, 2020. Coauthor.
  • “Mississippi Supreme Court Holds Tolling Provision Applies to Department, Not Taxpayers,” SeeSALT, May 15, 2020.
  • “Missouri Supreme Court Ends Longstanding Practice of Applying Use Tax Definitions in Sales Tax Cases,” SeeSALT, April 7, 2020.
  • “No Sales or Use Tax Due on Materials and Equipment Used to Construct and Install Steam Facility at Tennessee Manufacturing Plant,” SeeSALT, March 26, 2020.
  • “South Carolina ALC Says Pipeline Company’s Assets May Qualify for Pollution Control Equipment Exemption,” SeeSALT, March 10, 2020.
  • “Massachusetts Supreme Judicial Court Upholds Massachusetts Sales Tax on Screen-Sharing Software Products,” SeeSALT, February 6, 2020.
  • “Illinois Taxpayers Score Rare TIA Win in Property Tax Dispute,” SeeSALT, January 31, 2020.

• Press Mentions

  • “Tennessee Taxpayers Could Reap Billions in Past and Future Tax Savings,” Law360, July 5, 2024.
  • “Panelists Discuss Challenges of True Object Test for Mixed Transactions,” Tax Notes State, October 26, 2023.
  • “Litigation May Clarify ‘Look-Through’ Sourcing, Attys Say,” Law360, July 18, 2023.
  • “Concerns Seen With States’ Market-Sourcing Rulemaking, Panel Says,” Tax Notes, October 25, 2022.
  • “‘Look-Through’ Sourcing Causes Many Disputes, Panelists Say,” Law360, October 21, 2022.
  • “Panelists Outline Challenges of Market-Based Sourcing, Cost of Performance,” Tax Notes Today State, November 1, 2021.
  • “Market-Based Sourcing Raises Tricky Questions, Pros Say,” Law360, October 28, 2021.
  • “Florida Governor Signs Economic Nexus Bill,” Tax Notes, April 21, 2021.