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.

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

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