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:
SALT partners Aruna Chittiappa and Evan Hamme will be presenting at COST’s 2025 Spring Conference taking place April 28 – May 1, 2025.
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.
SALT partner Aruna Chittiappa will be presenting at TEI’s Midyear Conference on March 17.
Pillsbury SALT partner Breann Robowski will present at the 2025 ABA-IPT Advanced Property Tax Seminar on March 13.
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.
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.
On September 28, 2024, California enacted Assembly Bill 2854, which imposes new disclosure requirements on local agencies (i.e., chartered or general law cities and counties) that have entered into local sales tax sharing agreements with retailers. Generally, pursuant to a local sales tax sharing agreement, a retailer will agree to establish a new sales or fulfillment center in a local jurisdiction and source its sales to that local jurisdiction. In exchange, the local jurisdiction will provide the retailer a rebate on the local sales tax revenue generated for the local jurisdiction.
Pillsbury SALT partner Craig Becker will be presenting at the California Alliance of Taxpayer Advocates 2024 Annual Conference on December 12.
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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