Carley Roberts

Firm: Pillsbury Winthrop Shaw Pittman LLP
Location: Sacramento - CA

  • 500 Capitol Mall Suite 1800
    Sacramento, CA 95814
    USA
  • Tel : 916.329.4700
  • Fax : 916.441.3583
  • Linkedin.Logo
  • Twitter.Logo

Carley Roberts, leader of Pillsbury’s State and Local Tax practice, advises Fortune 100 and industry-leading companies on all aspects of state and local tax matters. Her clients comprise a variety of industries, including energy, technology, telecommunications, media, retail and manufacturing.

Described by clients as an “exceptional advocate for her clients” and “truly one of the best tax lawyers that I have had the privilege to work with” (Chambers 2018), Carley’s practice consists of administrative and judicial litigation, state and local tax planning and transactional work involving all U.S. state and local jurisdictions, where she has litigated numerous precedent-setting matters. These matters impact critical questions on apportionment, combination, exemptions and credits, nexus and constitutional violations involving income, sales and use, and property tax and all areas of local taxation. Particularly recognized for her leadership in California, Carley has successfully represented hundreds of matters before California’s tax agencies, administrative tribunals and courts.

Carley has been the recipient of numerous awards and is regularly featured in the legal profession’s “best of” and “who’s who” lists. In addition to being named as one of the 2016 Top 10 Outstanding Women in Tax for having a significant impact on tax practice and tax policy and 2014 Tax MVP of the Year for having the biggest wins and making the most significant contributions to the state and local tax (SALT) community, she was also recognized as a key influencer in SALT and was featured in the State Tax Today “State Tax Spotlight.”

Carley is past chair of the Taxation Section of the California State Bar. She is known for resurrecting the California Tax Policy Conference–the leading conference on developments in the bellwether state for state tax policy. In addition to being a sought-after speaker, Carley contributes to publications such as Tax Analysts’ State Tax Notes and BNA’s Tax Management Weekly State Tax Report.

REPRESENTATIVE EXPERIENCE

  • Secured $300 million victory before the California Franchise Tax Board for a Fortune 20 energy company involving complex formulary apportionment issues.
  • Won the first corporate business tax appeal to go to a full hearing before the California Office of Tax Appeals.
  • Secured $150 million win before the California Franchise Tax Board for a Fortune 20 technology company involving inclusion of OEM licensing receipts in the sales factor, research and development credits, and other multistate income tax issues.
  • Represents a Fortune 20 technology company in a case of first impression against the City and County of San Francisco involving the exclusion of investment receipts from the Gross Receipts Tax.
  • Secured a win before the Pennsylvania Board of Finance and Revenue on corporate net income and franchise tax appeals involving interest expense deductions on behalf of a Fortune 200 consumer food company.

Honors & Awards

  • Recipient, Benjamin F. Miller Award (2023)
  • Ranked Band 1 by Chambers USA in the area of State and Local Tax for over a decade (2007 – 2008, 2011 – 2023)
  • Ranked by the Best Lawyers in America guide for Tax Law (2023 – 2024); Litigation and Controversy – Tax (2024)
  • Featured by California Lawyers Association’s “Toast to Women in Tax: Inspiring Leadership” (2022)
  • Named one of Tax Analysts’ “Outstanding Women in Tax” (2016)
  • Named Super Lawyer in the area of Tax by Northern California Super Lawyers (2011 – 2022)
  • Recognized by The Legal 500 U.S. in the area of tax controversy (2015)
  • Recipient of Law360’s “Tax MVP of the Year” (2014).
  • Recipient, V. Judson Klein Award (2013)
  • Recipient, The Wiley W. Manual Award for Pro Bono Legal Services (2005 – 2012)

Publications

  • “California Trial Court Grants Industry Trade Association’s Motion for Summary Adjudication, Declaring Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid,” SeeSALT Blog Post, with Jeffrey Vesely and Nolan Kessler, December 20, 2023.
  • “California Trial Court Rejects Industry Trade Association’s Motion for Summary Judgment Seeking to Declare Technical Advice Memorandum 2022-01 and FTB Publication 1050 Invalid,” SeeSALT Blog Post, with Jeffrey Vesely and Nolan Kessler, September 21, 2023.
  • “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,’” Pillsbury Client Alert, with Craig Becker, Zachary Atkins, and Richard Nielsen, June 9, 2023.
  • “No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit,” SeeSALT Blog Post, with Jeff Phang, May 17, 2023.
  • “UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT Blog Post, with Jeff Phang and Robert P. Merten III, March 8, 2023.
  • “Property Tax Rate Disputes Merits California Supreme Court Review,” Tax Notes State, with Craig Becker, Breann Robowski, Robert P. Merten III, and Joseph Chan, February 13, 2023.
  • “California Proposes Significant Revisions to Sales & Use Tax Statistical Sampling Audit Policies and Procedures,” SeeSALT Blog Post, with Richard Nielsen and Nolan Kessler, February 8, 2023.
  • “California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT Blog Post, with Robert P. Merten III and Jeff Phang, January 23, 2023.
  • “Texas Court of Appeals Confirms Cost-of-Performance Method Is Proper to Source Service Receipts,” SeeSALT Blog Post, with Evan Hamme and Taylor A. F. Wolff, November 28, 2022.
  • “The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules,” SeeSALT Blog Post, with Jeff Phang, October 24, 2022.
  • “Industry Trade Association Sues California Franchise Tax Board Over “Radical” New Interpretation on Scope of Public Law 86-272 Post-Wayfair,” SeeSALT Blog Post, with Robert P. Merten III and Nolan Kessler, October 10, 2022.

Education

  • J.D., University of the Pacific, McGeorge School of Law, 1999
    with honors, Associate Editor, Transnational Lawyer
  • B.S., Brigham Young University, 1996
    with honors

 

Pillsbury Winthrop Shaw Pittman LLP

Pillsbury’s transactional and controversy tax lawyers are regularly recognized for excellence by Chambers USA, The Legal 500 U.S. and U.S. News – Best Lawyers.

Pillsbury tax lawyers advise on a range of complex transactions and represent a blue chip list of clients in state and local (SALT) and federal controversies. Our transactional tax lawyers structure and negotiate domestic and cross-border M&A, finance, securities and securitization transactions as well as advise on restructurings, private investment funds and real estate investments (including REITs). We have a nationally recognized Tax-Advantaged Investment and Housing Finance practice and regularly structure and document energy credit transactions.

Our SALT litigators have represented 20 percent of the Fortune 50 on state and local tax controversies in jurisdictions across the U.S. involving income and franchise tax, sales and use tax and an array of miscellaneous taxes. Our real and personal property tax team regularly achieves multimillion-dollar savings for many California-based clients as well as others. Our federal controversy practice focuses on inter-company pricing challenges and the expanding international reporting and compliance rules that ensnare financial institutions, cross-border investors and non-U.S. individuals. Pillsbury tax lawyers also advise tax-exempt organizations and family offices and assist our Estates, Trusts & Tax Planning and Executive Compensation & Benefits practices on complex income tax matters. Our Pillsbury Tax Page keeps you on top of tax law developments.