SALT Impact of TCJA

Revisiting California Tax Residency after the TCJA

Posted January 1, 2019

(This article originally appeared in the Journal of Multistate Taxation and Incentives, Vol. 28, No. 9.)

The question of whether or not an individual is a resident of a particular state has always been an important issue in the area of state personal income taxation. California, because of its top marginal personal income tax rate of 13.3 percent¹, and the large number of high-wealth individuals living in the state, always has been one of the most significant jurisdictions for this issue. Indeed, California, at 13.3 percent, currently has the highest personal income tax rate of any state.² The significance of the high California rate, and the residency issue in general, recently has taken on added significance as a result of two federal tax law changes.

Continue Reading ›

“Federal Tax Changes Rocking the SALT Landscape”

Posted November 16, 2018

by Pillsbury SALT

Pillsbury SALT

On November 16, Carley Roberts presents “Federal Tax Changes Rocking the SALT Landscape” during Tax Executives Institute’s New Jersey All-Day Seminar.

Fund Managers Face Tax Hike If California Passes AB 2731

Posted June 20, 2018

by Tim Gustafson and Pillsbury SALT

Tim Gustafson

Pillsbury SALT

(This article was originally published by Law360.)

California’s A.B. 2731 seeks to accomplish what the federal Tax Cuts and Jobs Act did not, namely, to close the carried interest “loophole.” Currently making its way through state assembly committees, AB 2731 would impose an additional 17 percent tax on interest income derived from investment management services on taxpayers subject to California’s personal income tax law.