The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s California apportionment formula and is not sourced 100 percent to the nonresident shareholder’s domicile. Continue Reading ›
Articles Posted in Income Tax
2022 Summer Tax Institute
Pillsbury SALT partner Robert P. Merten III will be participating as an instructor in the 2022 Summer Tax Institute put on by the UC Davis School of Law.
CalTax’s 96th Annual Meeting
Pillsbury SALT partner Carley Roberts will be participating in a panel discussion on income tax at the CalTax Annual Meeting on June 2.
2022 ABA/IPT Virtual Advanced Tax Seminars
Pillsbury SALT partner Breann Robowski will present during the 2022 ABA/IPT Virtual Advanced Tax Seminars in March.
California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by 2020 Legislation
California Governor Gavin Newsom has signed legislation (i.e., S.B. 113) to, among other things, reinstate business tax credits and net operating loss (NOL) deductions originally limited by the enactment of A.B. 85 in 2020.
TEI Chicago Virtual State Income Tax Program
Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Robert Merten III, Aruna Chittiappa and Jeff Phang will present during the TEI Chicago Virtual State Income Tax Program on December 9.
Taxpayer Files Court Action Challenging California’s Proposition 39 (2012) and its Mandatory Single-Sales Factor Apportionment Formula
In One Technologies LLC v. Franchise Tax Board, an out-of-state California corporate taxpayer filed suit in California trial court challenging the state’s mandatory single sales factor apportionment formula on the basis its passage in 2012 via voter initiative Proposition 39 unconstitutionally violated the “single subject rule.”
Telework Nexus Burdens Grow As States Shed Pandemic Relief
Pillsbury Counsel Evan Hamme discussed how the rise in remote work could lead to tax compliance issues for employers with Law360. Read more here. Continue Reading ›
California Lawyers Association’s 2021 Annual Income Tax Seminar
Pillsbury SALT attorneys Robert Merten and Lexi Louderback will present during CLA’s Annual Income Tax Seminar on July 15.
Delaware Court Invalidates Division’s NOL Limitation Policy
Pillsbury State & Local Tax special counsel Zachary Atkins explores the recent Delaware court decision of Verisign and the implications it has for taxpayers in Tax Notes State’s SeeSALT Digest.