A divided panel of the California Office of Tax Appeals (OTA) held that a California cabinet contractor owed use tax on fabrication labor bought from his Mexican affiliate. The panel found that the sale took place in Mexico, not California.
The taxpayer, a sole proprietor doing business as Carmel Mountain Cabinetry, builds and installs custom
In Tesoro Refining & Mktg. Co. LLC v. City of Carson, the California Supreme Court held that the Government Claims Act (GCA) preempts local governments from requiring taxpayers to comply with local administrative review procedures before filing a tax refund claim. Tesoro operates a refinery in the City of Carson, California, which, in 2017
On September 1, 2026, the California Department of Tax and Fee Administration (CDTFA) published a Discussion Paper, including proposed emergency regulations (Draft Regulations) that would amend existing sales and use tax regulations and adopt new ones, on the application of the sales and use taxes to digital products. The Discussion Paper is CDTFA’s first
On Wednesday, August 26, 2026, join SALT attorneys Tim Gustafson and Eric Coffill at 3 p.m. ET for another California tax update webinar, where they will examine key California tax developments and what they mean for taxpayers. The discussion will cover a new sales tax on software, important tax cases making their way through the
The California Office of Tax Appeals (OTA) held that severance payments and employer-paid medical premiums received following an employee’s termination constituted income from intangible personal property and were therefore sourced to the taxpayer’s Nevada domicile. The taxpayer, a former California-based bank CEO, was terminated without cause in late 2015, relocated to Nevada around the same
California has enacted one of its most significant sales tax changes in decades, expanding the state’s sales tax base to include electronically delivered and remotely accessed software. In this episode of the SALT Shaker Podcast, hosts and Partners Jeremy Gove and Chelsea Marmor are joined by Partners Michele Borens and Charlie Kearns, both of whom
In The Retail Property Trust v. Orange County Assessment Appeals Board No. 1, the California Fourth District Court of Appeal affirmed the denial of property tax disaster relief to the owner of the Brea Mall, holding that neither COVID-19-related closure orders nor the virus itself constitute the “physical damage” required for calamity reassessment under Revenue
The California Court of Appeal held that a Texas radiologist did not owe California personal income tax because it did not operate a unitary business in the state. During the years at issue, a medical corporation sent the Texas radiologist imaging studies collected at medical facilities in other states, including California. He then read the
The California Legislature may vote today on the Governor’s tax provisions, including sales tax on software. For additional background, see materials from our recent webinar on the proposal. The state Constitution requires the Legislature to pass a budget bill by June 15 at midnight. The Constitution also requires that a bill be in print for
The California Office of Tax Appeals held that storing inventory at a third-party warehouse constitutes “doing business” for income and franchise tax purposes.
The taxpayer was a Pennsylvania-based corporation making online sales of apparel through a third-party digital marketplace. The taxpayer also contracted with the marketplace to hold and ship inventory from warehouses (fulfillment centers)
