In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more
The California Franchise Tax Board (FTB) has proposed amendments to its regulations that govern how sales of services and intangibles are sourced for income tax purposes. The changes to this income tax apportionment...more
In a year that has seen sweeping changes to the state tax landscape brought about by the Tax Cuts and Jobs Act’s (TCJA) revisions to the Internal Revenue Code (I.R.C. or Code), the majority of state tax focus—with good...more
The year 2018 has been a monumental one for the state and local tax community. If the sweeping changes to the US federal tax code made by the federal Tax Cuts and Jobs Act of 2017 (TCJA) and continued efforts by the states to...more
11/2/2018
/ Capital Gains ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
U.S. Treasury
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
4/26/2016
/ Add-Back Legislation ,
Consolidated Tax Returns ,
Debt ,
Foreign Affiliates ,
Franchise Taxes ,
Income Taxes ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Related Parties ,
State Taxes ,
Tax Deductions ,
U.S. Treasury