Pillsbury SALT partner Carley Roberts will participate as a panelist on an upcoming CalTax Foundation webinar on Tuesday, September 10. Join Carley as she presents on the topic, “Mass Appeal: Notable Decisions and Trends at the Office of Tax Appeals.” The panelists will discuss and provide updates on recent notable…
Pillsbury SALT partner Jeffrey Vesely will present during WSPA’s virtual event on October 13. Jeff will be speaking at this annual forum and providing an overview of the current status of taxpayer representation on indirect tax matters before the CDTFA, OTA and state courts. For more information, please login into the…
Pillsbury SALT partner Carley Roberts will participate in the CalTax Webinar series on August 24. The theme for the webinar is “How to Navigate the Appellate Process at the OTA.” During this webinar, the speakers will discuss their experiences working with the OTA and their thoughts on the administrative process.…
The California Office of Tax Appeals held the Franchise Tax Board abused its discretion in failing to abate interest for a 248-day delay caused by the FTB’s failure to assign a protest hearing officer to the taxpayer’s protest. Taxpayer wins involving interest abatement requests on appeal are fairly uncommon in…
The California Office of Tax Appeals will hold an informal interested parties meeting on April 3, 2020, to discuss proposed amendments to its rules for tax appeals. The proposed amendments are in response to feedback from public and internal parties after the OTA began operating under its permanent rules for…
(This article originally was published by Law360 on January 16, 2020.) The saga continues in Arizona v. California, Arizona’s U.S. Supreme Court challenge of California’s tax reach, but signs are strong it may be ending soon. Last year, Arizona filed a motion to the court seeking to file a complaint against California…
The California Office of Tax Appeals (OTA)—in a 3-0 pending precedential opinion granting the Appeal of Jali, LLC—has rejected the Franchise Tax Board’s (FTB) 0.2 percent ownership threshold as the new bright-line standard for determining whether an out-of-state LLC member is actively “doing business” (and thereby required to file and…
(This article was originally published by Law360 on April 16, 2019.) In recent years, many have openly criticized California for its income tax litigating position involving out-of-state companies that hold passive, minority interests in pass-through entities doing business in California. The state argues these out-of-state companies are doing business in California…