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
On March 25, 2022, the California Franchise Tax Board (FTB) issued Legal Ruling 2022-01, on the subject “Numerator Assignment of Gross Receipts from Sales of Services to Business Entities.” The ruling sets forth the FTB’s position regarding the “relevant considerations and proper analysis” for sourcing sales of services under California’s current market-based sourcing rules.
The California Office of Tax Appeals (OTA) recently sustained the Franchise Tax Board’s (FTB) income tax treatment of an IRC 338(h)(10) election. In return for all the outstanding stock in the target S-Corporation taxpayer, third-party buyers paid an initial (fixed) purchase price and agreed to make deferred contingent earnout payments totaling up to $50 million
On March 7, Eversheds Sutherland Partner Jeff Friedman will participate in a panel from Thomson Reuters ONESOURCE and Tax Executives Institute (TEI), covering important SALT trends and issues to watch in the coming year. For more information and to register, click here.
In addition, on March 9, join Eversheds Sutherland attorneys Tim Gustafson and
In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Associate Annie Rothschild to discuss some noteworthy developments in the proposed amendments to California’s market-sourcing regulations. They highlight changes to the regulations that Annie discusses at length in a recent Tax Notes State article.
They conclude
In this episode of the SALT Shaker Podcast focused on policy issues, host and Eversheds Sutherland Partner Nikki Dobay hosts a full house for a West Coast legislative update. Nikki welcomes back Rob Gutierrez, President and CEO of the California Taxpayers Association (CalTax), and Jeff Newgard, Principal and Owner of Peak Policy and also
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.
Today, California Governor Gavin Newsom signed budget trailer bill SB 113, allowing taxpayers to again fully utilize business tax credits, like the R&D credit, and net operating loss deductions for taxable years beginning on or after January 1, 2022. For tax years 2020 to 2022, AB 85 (enacted in 2020), limited the amount of
Introduced this week, California AB 87 implements Governor Gavin Newsom’s proposed budget plan to allow taxpayers to again fully utilize business tax credits, like the R&D credit, and net operating loss deductions in 2022 (see our previous coverage on Governor Newsom’s proposed budget here). For tax years 2020 to 2022, AB 85 (enacted in
