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 […]

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 […]

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 […]