The Minnesota Tax Court ruled that the federal Anti-Head Tax Act (AHTA) preempts using Alaska Airlines’ gross receipts when calculating the Minnesota Franchise Tax Minimum Fee. The AHTA prohibits states from taxing gross receipts from air commerce or transportation. Minnesota’s Minimum Fee, imposed on taxpayers exercising a corporate franchise in the state, is calculated based
The California FTB’s proposed market-sourcing regulation: Eight changes to watch
In this installment of A Pinch of SALT for Tax Notes State, Eversheds Sutherland attorneys Eric Coffill and Annie Rothschild review the Franchise Tax Board’s proposed amendments to California’s market-based sourcing regulation, including its conception and eight important changes to watch as it moves through the approval process.
Read the full article here.
GILTI and California
Currently, there is no California conformity to GILTI, and GILTI is not part of the tax law in California unless and until the California Legislature adopts it.
In this column for the November/December issue of Journal of Multistate Taxation and Incentives, Eversheds Sutherland attorneys Eric Coffill and Annie Rothschild discuss the California Legislature’s recent…
Five common challenges when changing state tax residency/domicile
Residency/domicile is a critical issue in a state-tax analysis because, as a general principle, a state taxes its own residents on all their income from whatever sources it is derived (typically with a credit mechanism for some or all tax paid to another state on that same income). However, regardless of residency and regardless of…
California legislative session ends with no major tax increase bills
The California Legislature adjourned on September 10 and ended the 2021 legislative session without passing any major tax increase bills during the session. Several proposals were under consideration during the early part of the session, but were not revived before adjournment.
In his article for Financial Advisor Magazine, Senior Counsel Eric Coffill describes important
The custom work of state tax
This installment of “Behind the Board,” which highlights the milestones, challenges, and lessons of Tax Notes State’s advisory board, focuses on Senior Counsel Eric Coffill.
Read more about Eric’s career and reflections here.
Webcast: How the events of 2021 have impacted the California tax landscape so far
In a world and state already riddled with uncertainty, California holds a recall election. Through it all, however, taxes remain a constant.
On September 15, join Eversheds Sutherland attorneys Tim Gustafson and Eric Coffill as they cover key tax events that occurred in California during the first three quarters of 2021 and how the recall…
Know when to fold ‘em – OTA rules taxpayers residents of California despite renting apartment in Nevada
A three-judge panel of California’s Office of Tax Appeals (“OTA”) issued a precedential decision ruling that taxpayers remained domiciled in and residents of California at the time they sold their aviation business despite renting an apartment in Nevada prior to purchasing a home in the same area.
At the time of the sale, the taxpayers…
New York Tax Appeals Tribunal rules mandatory S corporation election triggered based on IRC definition of income
On May 17, 2021, the New York Tax Appeals Tribunal (Tribunal) held that when determining whether a New York C corporation must mandatorily elect to be treated as an S corporation as a result of the investment ratio test provided by New York Tax Law § 660(i), such test requires that “federal gross income” adopt…
California’s Latest Wealth Tax Proposal: An Overview of AB 310