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Articles Posted in Income Tax

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California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms

Following the IRS’s announcement of tax relief for 41 California counties* affected by severe winter storms, the California Franchise Tax Board (FTB) and California Department of Tax and Fee Administration (CDTFA) announced similar relief for state-level taxes and fees. The FTB automatically extended the filing and payment deadlines for businesses…

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The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules

In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by prematurely using reasonable approximation to source the income of a multistate unitary business.  During the tax year…

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Industry Trade Association Sues California Franchise Tax Board Over “Radical” New Interpretation on Scope of Public Law 86-272 Post-Wayfair

The American Catalog Mailers Association (ACMA), which describes itself as the nation’s leading industry trade association advocating for catalog, online, direct mail, and other remote-selling merchants and their suppliers, has filed suit against the California Franchise Tax Board (FTB) in the San Francisco County Superior Court of California. ACMA’s complaint…

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Pennsylvania Legislation Provides Updates to Corporate Income Tax Law

The Pennsylvania Governor signed H.B. 1342 to enact changes to the state’s corporate income tax.[1]  The legislation modifies the corporate income tax in three ways: (1) adopts a bright-line economic nexus standard; (2) adopts market sourcing for receipts from intangibles; and (3) reduces the corporate tax rate and gradually continues…

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California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the Entity Level.

The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s…

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2022 ABA/IPT Virtual Advanced Tax Seminars

Pillsbury SALT partner Breann Robowski will present during the 2022 ABA/IPT Virtual Advanced Tax Seminars in March. The Institute for Professionals in Taxation and the ABA Section of Taxation will once again host three jointly sponsored seminars in Sales Tax, Property Tax, and State Income Tax. These seminars will feature…

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California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by 2020 Legislation

California Governor Gavin Newsom has signed legislation (i.e., S.B. 113) to, among other things, reinstate business tax credits and net operating loss (NOL) deductions originally limited by the enactment of A.B. 85 in 2020. At the beginning of the pandemic, California anticipated the state would face a large tax revenue…