Ever-dependable California has stepped up to the plate and become the first state to require the submission of a federal Schedule Uncertain Tax Position Statement (Schedule UTP). The Franchise Tax Board (FTB) announced on December 1, 2010 that, for taxable years beginning on or after January 1, 2010, it will require taxpayers that file federal
California
California SBE Characterizes Gain from “Deemed” Sale of Goodwill as Business Income
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Posted in California, Noteworthy Cases
In In re Appeal of Imperial, Inc., Case Nos. 472648; 477927 (July 13, 2010), the California State Board of Equalization (SBE) ruled that gain from the sale of stock sold pursuant to an IRC § 338(h)(10) election constituted business income. Imperial, Inc., a Wisconsin S corporation, entered into an acquisition agreement with an unrelated…
The California Tax Shakeup
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Posted in California, Policy and Legislation
Chaos resulting from the California budget crisis reached a crescendo in recent weeks because of a new budget agreement, a bevy of voter referendums addressing tax legislation, and new regulations addressing corporate income tax apportionment issues. In the aftermath of the chaos, California has again significantly modified its corporate income tax apportionment provisions, for…
California FTB to Hold Meeting on Intercompany Transactions, DISA Reporting
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Posted in California, Policy and Legislation
The California Franchise Tax Board (FTB) will hold its second interested parties meeting on September 22, 2010, at 1:00 p.m. PDT to discuss revisions to Regulation 25106.5-1, which addresses intercompany transactions. The meeting will address comments and proposed amendments submitted after the first interested parties meeting held in April of this year.
The purpose…