SeeSALT BlogArticles Posted in Income Tax
2025 Summer Tax Institute
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Pillsbury SALT partner Robert P. Merten III will be an instructor for the 2025 Summer Tax Institute, hosted by the UC Davis School of Law.
California Legislature Advances Broad Federal Tax Conformity Bill (SB 711)
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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:
COST 2025 Spring Conference
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SALT partners Aruna Chittiappa and Evan Hamme will be presenting at COST’s 2025 Spring Conference taking place April 28 – May 1, 2025.
California OTA Denies Credit for NYC Business Taxes in Precedential Opinion
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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 State (NYS) did not require NYC to impose the UBT. The OTA also held that the NYS Metropolitan Commuter Transportation Mobility Tax (MCTMT) met the requirements to claim the OSTC, but that the taxpayers failed to substantiate the amount of their claim.
COST Pacific Northwest Regional State Tax Seminar
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SALT attorneys Zachary Atkins, Evan Hamme, Taylor Wolff and Breanna Zagorski will be presenting at the COST Pacific Northwest Regional State Tax Seminar on December 5.
California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16
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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.
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COST’s 2024 SALT Workshop for Technology Companies
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Pillsbury SALT attorneys Carley Roberts, Jeffrey Vesely, Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present at this year’s SALT Workshop for Technology Companies on August 14 and 15.
NYU Introduction to State and Local Tax Conference
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Pillsbury SALT attorney Aruna Chittiappa will be presenting at NYU’s Introduction to State and Local Tax conference taking place July 22-23, 2024 in New York.
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
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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 Corporation & Subsidiaries (Appeal of Microsoft) and by granting the Franchise Tax Board’s (FTB) quasi-legislative rulemaking authority exempt from the procedural protections afforded by the Administrative Procedure Act. The May Revision also proposes to suspend net operating loss (NOL) deductions and limit tax credit utilization to $5 million per year for tax years 2025-2027; however, the legislature proposes to apply the changes to tax years 2024-2026 instead.