Articles Posted in Issues

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Pillsbury SALT is excited to welcome back Annie H. Huang to the team!

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Annie’s experience focuses on state and local tax matters, including corporate franchise and income, personal income, sales and use, and gross receipts and other local taxes.

Annie brings not only strong legal experience but also a genuine enthusiasm for building relationships and supporting clients through complex challenges.

She joins Pillsbury’s San Francisco office as a partner.

 

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OTA

The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the issuing agency, but its authority extends to setting aside the regulation for that appeal. OTA lacks authority to invalidate or repeal the regulation more broadly or to apply its conclusions outside the specific appeal.

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Senate Bill 711 (S.B. 711) would update California’s conformity date to the Internal Revenue Code (IRC) from January 1, 2015, to January 1, 2025. If enacted, this change would apply to taxable years beginning on or after January 1, 2025, and would align California tax law with numerous federal provisions enacted over the past decade. Notable provisions include:

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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 (CalTax) and the Silicon Valley Leadership Group (SVLG) also submitted their comments in a joint letter.

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