Yearly Archives: 2020
It’s Time To Invalidate Single-Sales Factor For Biz Income Tax
Law360 (December 7, 2020) — We predict the 2020s will see just as seismic a shift in state tax constitutional law as the 2010s did with South Dakota v. Wayfair Inc.[1] Single-sales-factor apportionment will be subjected to a modern, nuanced judicial analysis, and another decades-old foundational precedent, Moorman Manufacturing Co. v. Bair[2] — upholding single-sales […]
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Taxpayers Entitled to Refund for 2011 Sale of Stock, OTA Rules
CalTaxletter (December 4, 2020): Two taxpayers were entitled to a refund of $423,695 for the 2011 tax year, the Office of Tax Appeals concluded in an October 21 ruling in the Appeal of L. Conacher and J. Dea. In its 2-1 ruling, the OTA additionally denied the Franchise Tax Board’s proposal of $20,120 of additional […]
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State Supreme Court Lets Taxpayers’ Win Stand in Case Involving Tax on Liquid Storage Capacity
CalTaxletter (January 17, 2020): The California Supreme Court this week denied review of a Court of Appeal ruling that invalidated a tax in Rialto as an invalid real property tax. The high court’s January 15 action leaves in place the taxpayer’s win in Tesoro Logistics Operations, LLC et al. v. City of Rialto. In its […]
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