In the October 2023 edition of Spidell’s California Taxletter, Eversheds Sutherland Senior Counsel Eric Coffill shares six tips for settling tax matters with the FTB and the
CDTFA.
Read the full article here.
Wading through the water’s-edge combined reporting method
This episode of the SALT Shaker Podcast welcomes a new voice into the mix, Eversheds Sutherland Associate Laurin McDonald. Laurin joins host and Associate Jeremy Gove to describe 80/20 rules used by states in the context of water’s-edge combined reporting, the subject of an article she co-authored in Tax Notes State.
In addition to
How gross! San Francisco’s troubled tax system
There has been an alarming expansion of local taxes. In some localities, this includes new local taxes imposed on businesses. In other localities, this includes aggressive interpretations of existing local ordinances by local tax agencies.
In this installment of A Pinch of SALT in Tax Notes State, Eversheds Sutherland attorneys Michele Borens, John Ormonde
The evolution of market sourcing in California
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Partner Tim Gustafson joins Associate Jeremy Gove for a deep dive into California’s market-based sourcing regulation.
Together they discuss various interpretations of and proposed amendments to the regulation offered over the past six years, and how the interpretations and amendments might affect taxpayers.
They wrap
New York state and local tax update—second quarter 2023
In an article for Bloomberg Tax, Eversheds Sutherland attorneys Liz Cha and Jeremy Gove summarize recent tax developments in New York, including ones involving fiber-optic broadband and the treatment of buy-sell arrangements for petroleum products.
Read the full article here.
On the fence on deference: A turning point in state tax controversy
The power and reach of administrative agencies — often led by unelected officials — has long been a source of controversy. Nearly 40 years ago, in Chevron U.S.A. Inc. v. Natural Resources Defense Council Inc., the U.S. Supreme Court held that an administrative agency’s interpretation of a statute administered by that agency should be given deference
An interview with California FTB Deputy Chief Counsel Shane Hofeling
In this installment of Across State Lines in Tax Notes State, Eversheds Sutherland Senior Counsel Eric Coffill interviews Shane Hofeling, deputy chief counsel and director of the California Franchise Tax Board’s Technical Resources Bureau.
Read the full article here.
California’s ongoing piecemeal approach to market sourcing
In this installment of A Pinch of SALT for Tax Notes State, Eversheds Sutherland Partner Tim Gustafson reviews California’s market-based sourcing regulation, various interpretations of and proposed amendments to the regulation offered over the past six years, and how the interpretations and amendments might affect taxpayers.
Read the full article here.
A Texas re-ride: Comptroller describes changes to R&D credit regs
On February 6, 2023, the Texas Comptroller of Public Accounts released a memorandum summarizing the internal-use software regulations related to the state’s franchise tax research and development credit and the sales tax R&D exemption. The comptroller significantly revised these regulations in 2021 and then reversed the revisions in 2022, causing confusion among members of the
Water’s-edge combined reports and 80/20 companies
The unitary combined reporting method for state corporate income taxation has been adopted by an increasing number of states. While combined reporting requirements vary significantly from state to state, nearly all combined reporting regimes require or allow a water’s-edge method that limits the members of a group return to entities that are incorporated in the