Articles Posted in Income Tax

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After nearly a decade in development, the California Franchise Tax Board (FTB) has finalized its amended market-based sourcing regulation under Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.

The regulation was approved by the Office of Administrative Law and filed with the Secretary of State on August 27, 2025.  The revised rules will apply to tax years beginning on or after January 1, 2026.  Among the most significant changes to the regulation are:Capture-2-300x101

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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.  Read more here.

 

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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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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.

 

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