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…
Articles Posted in California
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…
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…
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…
Pillsbury SALT Team Together in California for COST Tech
The Pillsbury SALT team had an incredible time last month at the COST SALT Workshop for Technology Companies in Cupertino, CA. Carley Roberts, Zachary Atkins, Craig Becker, Evan Hamme, Robert P. Merten III, Jeffrey Vesely, and Aruna Chittiappa were all panelists and presented on various topics at the workshop. The…
Technology Transfer Agreements: Latest Developments in California
In 1993, the California Legislature amended Revenue and Taxation Code (RTC) sections 6011 and 6012 to exclude from California sales and use tax amounts charged for intangible personal property transferred with a technology transfer agreement (TTA) if the TTA separately stated a reasonable price for the tangible personal property (TPP). Nine…
California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization
The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently rejected by the Office of Tax Appeal’s (OTA) decision in the Matter of the Appeal of Microsoft…
Proposed Initiative to Amend San Francisco Business Taxes
A proposed initiative (available here) is being circulated to place on the November 5, 2024 ballot, an ordinance amending the Business and Tax Regulations Code effective January 1, 2025. The proposal would initially decrease total business taxes by almost $100 million a year making it one of the biggest tax…
Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor
The California Office of Tax Appeals (OTA), in a decision marked “not precedential” in the Matter of the Appeal of Microsoft Corporation & Subsidiaries, held 100 percent of repatriated dividends under the Tax Cuts and Jobs Act (TCJA) must be included in the taxpayer’s sales factor denominator. First, the OTA…
Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes
The California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA) and California Employment Development Department (EDD) announced tax relief for certain California counties affected by severe winter storms. The FTB automatically extended the filing and payment deadlines for businesses and individuals in San Diego County (only),…