Yearly Archives: 2022

The Long Arm of California’s Market Sourcing and ‘Economic Nexus’ Standards–Reaching Nonresident Business Owners Everywhere

By Dakessian Law | September 8, 2022
Forbes (September 8, 2022):  The exodus of business owners leaving California raises an issue that may be counterintuitive for some—that California can and will tax the income of nonresidents who never set foot in the state. Unlike wages or compensation, which are typically taxed where services are performed, it is the footprint of the business […]
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Sourcing of Income to California and “Economic Nexus” Consequences for Nonresidents

By Dakessian Law | May 5, 2022
When it comes to the taxation of nonresidents, the California tax agencies—the Franchise Tax Board and the Office of Tax Appeals (“OTA”)—have held that a nonresident business owner, who never set foot in California (hereafter, the “State”), owed personal income taxes to the State. This is based on application of rules that look to the […]
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California Proposes New Wealth Tax

By Dakessian Law | February 24, 2022
Despite unexpectedly high personal income tax receipts exceeding forecasts by $9 billion for the first seven months of California’s 2022 fiscal year, Assembly Bill 2289 proposes raising even more revenue for the State, through a brand-new annual wealth tax. This brand-new levy would apply as follows: 1.5 percent on certain assets exceeding $1 billion ($500 […]
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Pennsylvania’s Intangible Expense Add-back Continues to have Unanswered Questions and Now Renewed Focus

By Dakessian Law | February 10, 2022
On February 8th, Pennsylvania’s intangible expense add-back statute received renewed focus in Governor Wolf’s budget proposal.  The add-back statute went into effect in 2015 and denies deductions for intangible expenses or costs with an affiliated entity, including interest expense if it was related to an intangible expense or cost.  (See 72 P.S. 7401(3)1.(t))  The add-back […]
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California Budget Proposal Encourages Investments Combating Climate Change

By Dakessian Law | January 25, 2022
California has been a longtime supporter of clean-energy investments.  Next year’s proposed budget promises to offer even more statutory credits and incentives.  The plan includes additions to the current R&D credit for companies headquartered in California that invest in activities and technologies mitigating climate change. In addition, California plans to invest an additional $6.1 billion […]
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Louisiana’s Transfer Pricing Managed Audit Program Expires April 30, 2022

By Dakessian Law | January 21, 2022
The Louisiana Department of Revenue’s (Department) voluntary initiative (RIB No. 21-029) for corporate income taxpayers will expire before you know it.  The last few years have seen lengthy and complex Department field audits resulting in significant transfer pricing adjustments which make this program attractive to eligible taxpayers with numerous domestic intercompany transactions. There are clear benefits […]
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