The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
10/31/2023
/ Administrative Hearings ,
Corporate Restructuring ,
Franchise Tax Board ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Non-Residents ,
Pass-Through Entities ,
Residency Status ,
S-Corporation ,
Sale of Assets ,
State Taxes ,
Subsidiaries
In a recent memorandum issued by the Office of Chief Counsel, the Internal Revenue Service (IRS) concluded that many "NIL Collectives" may not qualify as tax-exempt under Section 501(c)(3) of the Internal Revenue Code of...more
6/27/2023
/ 501(c)(3) ,
Colleges ,
Fundraisers ,
Internal Revenue Code (IRC) ,
IRS ,
Name and Likeness ,
NCAA ,
Policy Memorandums ,
Student Athletes ,
Tax Exempt Entities ,
Universities
A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more
6/7/2022
/ Apportionment ,
Asset Purchase Agreements ,
Business Income ,
Family Trusts ,
Franchise Tax Board ,
Goodwill ,
Income Taxes ,
Internal Revenue Code (IRC) ,
S-Corporation ,
Sale of Assets ,
Shareholders ,
State Taxes ,
Subsidiaries ,
Tax Liability