Business owners operating in California are likely aware of state employment tax and workers' compensation insurance requirements. Many, however, might be unaware of local business tax and related requirements. Local Business Taxes and Fees Local government entities...
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FTB
Mexican Land Trust arrangements deemed not to be Trusts under Treasury Regulation section 301.7701-4(a)
Revenue Ruling 2013-14 describes a typical Mexican Land Trust (MLT), or fideicomiso, and concludes that the arrangement is not a trust within the meaning of § 301.7704-4(a).
California Source Income Tax Rate Determined On Worldwide Income for Non-California Residents
A recent California State Board of Equalization (BOE) decision illustrates California's broad reach to tax non-residents. Specifically, the California Franchise Tax Board (FTB) was able to successfully argue that additional tax was due from a non-California resident...
FTB to Hold Interested Party Meeting Concerning Its Financial Institution Program that Identifies Accounts of Delinquent Tax Debtors.
The Franchise Tax Board (FTB) is having a public hearing regarding its Financial Institution Records Match (FIRM), one of its most important tools in the collection of delinquent tax liabilities. The hearing is scheduled for 1:00 p.m., on Wednesday, March 27, 2013, at...
FTB Loses against an Out-of-State Nevada Corporation Owned by California Resident
In February, the Franchise Tax Board (FTB) lost a case, DANIEL V INC. v. Franchise Tax Board, in a Los Angeles Superior Court where it had asserted that a Nevada Company was commercially domiciled in California because it was owned by a California resident, Ron Lane....
FTB Shares Common Tax Issues for Corporations
The California FTB shared some of the most common tax audit issues for corporations today. Heading the list is the cost of performance and sourcing of intangible sales, along with sales factor and gross receipts, abusive tax shelters and credits. If you have questions...
BNA Article Argues that Quill Safe Harbor Extends to Sales of Intangibles Through the Internet.
The Bureau of National Affairs (BNA) has published an article which argues that the activities involved in selling intangible goods, such as songs and digital books, by means of the Internet are not sufficiently connected to states so as to permit states to tax them....
Franchise Tax Board Issues Ruling On Throwback Rule
The California Franchise Tax Board (FTB) recently issued a Chief Counsel Ruling 2012-03 addressing the throwback rules applied to sales made, by California based corporations, to purchasers located in foreign jurisdictions and other states. The throwback rule under...
FTB Advises Taxpayers on Gillette
On October 2, 2012, the Court of Appeal issued its decision in Gillette v. Franchise Tax Board. The case revolved around the issue of whether taxpayers could elect to utilize the apportionment formula contained in the Multistate Tax Compact instead of the mandatory...
California Couple Receives Prison Sentence in Offshore Account Tax Evasion Case
Sean and Nadia Roberts of Tehachapi, California, pled guilty before the Eastern District of California to a criminal information charging them with filing a false tax return under Internal Revenue Code § 7206(1). The charge is related to an undisclosed Swiss bank...
