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…
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…
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…
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…
Pillsbury SALT partner Robert P. Merten III will be participating as an instructor in the 2022 Summer Tax Institute put on by the UC Davis School of Law. The 32nd annual Summer Tax Institute is scheduled for June 13-16, 2022. It is an intensive, four-day educational program for tax professionals.…
Pillsbury SALT partner Carley Roberts will be participating in a panel discussion on income tax at the CalTax Annual Meeting on June 2. Carley is partnering with Shail Shah (Reed Smith LLP) and Michael Vigil (Andersen) to discuss the topic, “Navigating California Income Tax: An Essential Update on the FTB.”…
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…
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…
Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Robert Merten III, Aruna Chittiappa and Jeff Phang will present during the TEI Chicago Virtual State Income Tax Program on December 9. Pillsbury SALT is pleased to share three presentations during the TEI Chicago Virtual State Income Tax Program in December. State Income…
In One Technologies LLC v. Franchise Tax Board, an out-of-state California corporate taxpayer filed suit in California trial court challenging the state’s mandatory single sales factor apportionment formula on the basis its passage in 2012 via voter initiative Proposition 39 unconstitutionally violated the “single subject rule.” Prior to 2013, most…