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.

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