During the last two meetings, MTC Staff has continued to discuss and receive feedback on the draft model rules applicable to investment partnerships. To date, the draft has been amended twice, and the current version can be found here. As currently drafted, the model would only apply
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.
New York is considering expanding its False Claims Act to “knowingly or illegally failing to file” a tax return.
Not only should the legislature reject the proposed legislation, New York should roll back its FCA so it does not apply to taxes.
In this installment of “A Pinch of SALT” in Tax Notes State,
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
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
“Business-friendly” Texas has been the leading poacher of California-based companies for over a decade, with relocations from tech-dominated California only accelerating during the pandemic. Oddly enough, at a time when Texas’s highest-profile new neighbors are known for cutting-edge research, the state seeks to narrow the scope of its research and development credit applicable to some
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 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.
