Yesterday, the California Franchise Tax Board convened a public meeting to discuss tax compliance within the growing gig economy and the challenges of meeting these obligations. Speakers from academia, the FTB, the business community, and gig workers themselves, discussed various tax issues, three of which stood out. First, California’s nonconformity…
(This alert was also published as a bylined article by Law360 on July 31, 2015.) Over five years into a personal income tax residency audit by the California Franchise Tax Board (FTB), Gilbert Hyatt filed a civil suit in Nevada state court against FTB alleging tortious conduct by FTB auditors.…
The California Franchise Tax Board has issued a chief counsel ruling stating that a registered broker-dealer must include the entire sales price received from the sale of securities—including the return of capital—in the sales apportionment factor. Interestingly, the chief counsel determined that California’s alternative apportionment provisions do not apply to…
Beginning August 1, California income taxpayers that used a tax shelter or that have unreported income from the use of an offshore financial arrangement for tax years beginning before January 1, 2011, will have the opportunity to pay tax and interest on income related to those transactions and avoid a…
The California Franchise Tax Board (FTB) has recently issued a Legal Notice generally providing that taxpayers who previously filed incomplete IRS Forms 8886 or failed to file Forms 8886 with FTB will avoid penalties by filing completed forms within 60 days. Taxpayers that may have concerns regarding Form 8886 FTB…
The California water’s-edge election has proved immensely popular with both foreign and domestic parent corporations potentially engaged in a worldwide unitary business. Many elections are made to reduce or minimize California franchise tax, while others are made to simplify or reduce the compliance burdens under California’s worldwide combined reporting method.…
California corporate and individual taxpayers with pending audits, protests, appeals or settlement proceedings with the California Franchise Tax Board (FTB), or with comparable proceedings pending with he California State Board of Equalization (BOE) should pay particular attention to new penalties recently enacted by the Legislature and Gov. Arnold Schwarzenegger as…
On September 25, 2000, the California Franchise Tax Board (FTB) issued FTB Notice 2000-7, which requested public comment and gave notice of a symposium regarding a new proposed regulation relating to audit procedures. The FTB’s proposal is to add Regulation section 19032, “Audit Procedures,” to Title 18 of the California…