As part of its fiscal 2026 budget legislation (H.B. 352), Maryland enacted a significant change to its elective pass-through entity tax (PTET) regime. Effective for tax years beginning after December 31, 2025, the PTET base...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
Nonresidents of California generally are not taxed by California on gain resulting from the sale of partnership interests. Under new guidance issued by the California Franchise Tax Board ("FTB") nonresidents can now...more
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