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California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

On January 10, 2025, California Governor Gavin Newsom released his January Budget Proposal for the 2025 – 2026 fiscal year. Notably, Governor Newsom’s budget would increase tax revenue by requiring banks and financial corporations to move from an equally weighted three-factor formula, comprising property, payroll and sales factors, to a single-sales-factor formula…

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Technology Transfer Agreements: An Update on Latest Developments in California

The California Department of Tax and Fee Administration (CDTFA or Department) hosted its third workshop (Workshop III) on December 9, 2024, to discuss and receive input on technology transfer agreements (TTAs). On January 22, 2025, the CTIA (formerly the Cellular Telecommunications and Internet Association) submitted comments. The California Taxpayers Association…

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California OTA Denies Credit for NYC Business Taxes in Precedential Opinion

In the Appeal of Mather, the California Office of Tax Appeals (OTA) held in a precedential opinion that New York City’s (NYC) Unincorporated Business Tax (UBT) was not a tax “imposed by and paid to another state,” as required to claim the Other State Tax Credit (OSTC), because New York…

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California Imposes Further Disclosure Requirements for Local Sales Tax Sharing Agreements

On September 28, 2024, California enacted Assembly Bill 2854, which imposes new disclosure requirements on local agencies (i.e., chartered or general law cities and counties) that have entered into local sales tax sharing agreements with retailers. Generally, pursuant to a local sales tax sharing agreement, a retailer will agree to…

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2024 CATA Annual Conference

Pillsbury SALT partner Craig Becker will be presenting at the California Alliance of Taxpayer Advocates 2024 Annual Conference on December 12. Craig will discuss “Northern California Property Tax Appeals” at this year’s annual conference, which is being held at The Ritz-Carlton, Laguna Niguel from Wednesday, December 11 – Friday, December…

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2024 Annual Meeting of the Tax Bar and Tax Policy Conference

Pillsbury SALT attorneys Carley Roberts, Robert P. Merten III and Jeff Phang will present at this meeting, which will take place November 6-8. Robert P. Merten III: OTA Precedential Process Thursday, November 7, 10:50 AM – 11:50 AM Panelists will cover the precedential process, which includes nomination of cases, precedential…

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California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16

The California Franchise Tax Board (FTB) announced it has initiated the formal rulemaking process to amend Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.  The proposed changes would apply to taxable years beginning on or after January 1, 2024. The proposed amendments include several…

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California Lawyers Association Tax Policy Seminar

Pillsbury SALT partner Robert P. Merten III will present at a tax policy seminar hosted by the California Lawyers Association on October 18. Robert will be presenting on the topic, “California’s Approach to the Multistate Tax Base.” This program will examine California’s approach to determining the multistate tax base, including…

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Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs

The Arizona Court of Appeals held that an investment tax credit (ITC) deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property tax purposes.  In so holding, the court rejected the argument that an ITC has…