SeeSALT BlogPillsbury SALT attorneys Zachary Atkins, Craig Becker, Carley Roberts, & Richard Nielsen discuss California Assembly Bill 52. AB 52 would provide corporation and personal income tax credits for local sales and use and district taxes paid on machinery and equipment primarily used in manufacturing, research and development, electric power generation or production, or electric power storage and distribution.
Articles Posted in Income Tax
No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit
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The California Office of Tax Appeals (OTA) held a California resident was not entitled to claim an other state tax credit (OSTC) for taxes paid to Massachusetts because gain from the sale of an LLC membership interest was wholly sourced to the taxpayer’s domicile under California law. Continue Reading ›
2023 COST Intermediate/Advanced State Income Tax School
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Pillsbury SALT attorney Evan Hamme will be presenting at the 2023 COST Intermediate/Advanced State Income Tax School on May 8 in DFW Airport, Texas.
COST/CTC Mid-West Regional State Tax Seminar
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Pillsbury SALT attorneys Carley Roberts, Craig Becker, Zachary Atkins and Kristen Sharp will be presenting at the upcoming COST/CTC Mid-West Regional State Tax Seminar on Wednesday, May 3 in Rolling Meadows, Illinois.
TEI New York Chapter SALT Meeting
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Pillsbury SALT attorneys Craig Becker, Robert P. Merten III, Zachary Atkins, Evan Hamme and Aruna Chittiappa will present during TEI’s New York Chapter SALT Meeting on April 19 taking place at Pillsbury’s New York Office.
UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms
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In addition to the tax relief announced in January, the California Franchise Tax Board (FTB) has automatically extended the income tax filing and payment deadlines for businesses and individuals affected by severe winter storms in California until October 16, 2023.
2023 ABA/IPT Advanced Tax Seminars
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Pillsbury SALT partners Carley Roberts and Breann Robowski will be presenting during the 2023 ABA/IPT Advanced Tax Seminars in March.
California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms
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Following the IRS’s announcement of tax relief for 41 California counties* affected by severe winter storms, the California Franchise Tax Board (FTB) and California Department of Tax and Fee Administration (CDTFA) announced similar relief for state-level taxes and fees.
The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules
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In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by prematurely using reasonable approximation to source the income of a multistate unitary business. During the tax year 2017, the taxpayer operated a business providing in-person services as a horse racetrack judge in California and Minnesota but failed to file a California return. Related to such services, the taxpayer received Form 1099s from the State of California, the State of Minnesota, and Minnesota Harness Racing, Inc.
Industry Trade Association Sues California Franchise Tax Board Over “Radical” New Interpretation on Scope of Public Law 86-272 Post-Wayfair
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The American Catalog Mailers Association (ACMA), which describes itself as the nation’s leading industry trade association advocating for catalog, online, direct mail, and other remote-selling merchants and their suppliers, has filed suit against the California Franchise Tax Board (FTB) in the San Francisco County Superior Court of California.
ACMA’s complaint seeks a judicial declaration that the FTB’s 2022 publicly-issued guidance related to Public Law 86-272 (PL 86-272) – specifically, Technical Advice Memorandum (TAM) 2022-01 and FTB Publication 1050 – are invalid because (1) they contradict PL 86-272 and the U.S. Constitution; and (2) the FTB did not properly follow the California Administrative Procedure Act’s required rulemaking process before publishing such guidance. In the alternative, ACMA seeks a judicial declaration that the FTB’s new guidance applies on a prospective basis only. ACMA also seeks attorney’s fees and costs of suit for bringing the action to enforce an important right affecting the public interest.