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The Upland Ripple Effect: A California Supermajority Tax Showdown

Despite the narrow issue it originally addressed, the August 2017 decision by the California Supreme Court in California Cannabis Coal. v. City of Upland has sparked a much larger debate regarding whether local special taxes introduced by voter initiative are subject to the long-standing requirement in the California Constitution that…

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Transparency Versus Confidentiality in 2019 Tax Disputes

(This article was originally published by Law360 on January 15, 2019.) The growing tension between government promises of transparency and taxpayers’ right to confidentiality is likely to continue in 2019. Although the spirit of government transparency to enhance public access is well-meaning, this lofty goal often conflicts with taxpayer confidentiality and…

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Revisiting California Tax Residency after the TCJA

(This article originally appeared in the Journal of Multistate Taxation and Incentives, Vol. 28, No. 9.) The question of whether or not an individual is a resident of a particular state has always been an important issue in the area of state personal income taxation. California, because of its top marginal…

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SeeSALT Digest – The Exhaustion Doctrine and De Novo Review

In SeeSALT Digest, members of our team examine important issues in play in the State and Local Tax arena. In “Ill-Fated Litigation: Exhausting Administrative Remedies and De Novo Review,” published in State Tax Notes, colleagues Carley Roberts and Jessica Allen take a look at two of the more dangerous pre-litigation…