Earlier this month, the California Franchise Tax Board released Legal Ruling 2022-02, regarding the sourcing of Internal Revenue Code Section 751(a) gain from the disposition of a nonresident individual’s partnership interest when the IRC Section 751 property is located in California.
In this article for Law360, Eversheds Sutherland Senior Counsel Eric Coffill discusses
Most decisions issued by the California Office of Tax Appeals involve small dollars, but these decisions can still shape precedent.
In this article for Bloomberg Tax, Eversheds Sutherland Senior Counsel Eric Coffill discusses Appeal of R. Sheward, which addresses the Franchise Tax Board’s legal authority to assess tax on unreported income based on
Understanding—let alone navigating—the layers of bureaucracy is no small feat for taxpayers that seek to resolve a California tax controversy, whether through administrative protest and appeals processes or by means of settlement negotiations.
In many states, the counterpart from the department who handles a taxpayer’s protest or appeal also has authority to negotiate a settlement.
In this episode of the SALT Shaker Podcast policy series, Eversheds Sutherland Partner and host Nikki Dobay welcomes Chris Wright, Senior Vice President of Advance SF. Before getting into the weeds on San Francisco’s tax landscape, they cover the background of Advance SF and its mission to address issues that impact the ability of
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associates Jeremy Gove and Annie Rothschild delve into a recent decision out of the California Court of Appeal – Metropoulos Family Trust v. Franchise Tax Board. The court ruled for the Franchise Tax Board, affirming the trial court’s decision that non-resident S corporation shareholders
The California Court of Appeal ruled that nonresident shareholders were subject to California tax on their pro rata shares of intangible income from an S corporation’s sale of shares in a subsidiary. This sale of intangibles (goodwill of a business) was sourced as business income apportioned at the S corporation level, not as intangible income
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove teams up with Associate Cyavash Ahmadi to discuss the complexities of combined reporting, specifically comparing and contrasting the combined reporting regimes in New York and California. They discuss several of the nuances of both states’ systems and even debate what “Joyce v.
Until recently, it was generally assumed that a two-thirds vote was required for the passage of all local taxes imposed to fund a specific purpose, or special taxes, in California under the state Constitution. The 2017 California Supreme Court decision in California Cannabis Coalition v. City of Upland called this into doubt by holding in
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove speaks with Partner Tim Gustafson and Associate Annie Rothschild regarding California procedure and strategy considerations associated with the different options for challenging corporate tax deficiency assessments.
Tim and Annie recently authored an article in Tax Notes State addressing certain benefits and potential
It is still early in the 2022 session of the California Legislature, which reconvened on January 3, and goes on final recess on August 31. However, a number of proposals to increase taxes are already under consideration.
In his article for Financial Advisor Magazine, Eversheds Sutherland Senior Counsel Eric Coffill details current tax increase
