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California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment formula for financial institutions, aiming to increase tax revenue starting in tax year 2025. Update: On May 14, 2025, Governor Newsom released the May...more

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

California OTA Denies Credit for NYC Business Taxes in Precedential Opinion

In the Appeal of Mather, the California Office of Tax Appeals (OTA) held in a precedential opinion that New York City’s (NYC) Unincorporated Business Tax (UBT) was not a tax “imposed by and paid to another state,” as required...more

California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16

The California Franchise Tax Board (FTB) announced it has initiated the formal rulemaking process to amend Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.  The...more

California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit...

The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently...more

Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator....more

Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes

The California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA) and California Employment Development Department (EDD) announced tax relief for certain California counties affected by...more

No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit

The California Office of Tax Appeals (OTA) held a California resident was not entitled to claim an other state tax credit (OSTC) for taxes paid to Massachusetts because gain from the sale of an LLC membership interest was...more

UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by...

In addition to the tax relief announced in January, the California Franchise Tax Board (FTB) has automatically extended the income tax filing and payment deadlines for businesses and individuals affected by severe winter...more

The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules

In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by...more

California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the...

The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for...more

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