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California › Tax Appeals

McDermott Will & Emery

California Legislatively Overturns Recent Office of Tax Appeals Taxpayer Win

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The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more

McDermott Will & Emery

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

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The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

Allen Barron, Inc.

What Does the Recent OTA Ruling Tell You About a California Tax Audit?

Allen Barron, Inc. on

What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need...more

Pillsbury - SeeSalt Blog

“No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01”

Pillsbury - SeeSalt Blog on

In the Appeal of Southern Minnesota Beet Sugar Cooperative (2023-OTA-342P) (Beet Sugar), the California Office of Tax Appeals (OTA) issued a precedential opinion holding the California Franchise Tax Board (FTB) is not...more

McDermott Will & Emery

OTA Finds CDTFA’s Audit Methodology Arbitrary

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In Appeal of Colambaarchchi (OTA Case No. 21017152; 2023-OTA-302), a California-based retailer was audited by the California Department of Tax and Fee Administration (CDTFA) for years 2016 through 2019. Upon audit, CDTFA...more

McDermott Will & Emery

Buehler Doesn’t Get a Day Off from Double Taxation

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The California Office of Tax Appeals (OTA) recently held that a California resident’s income tax paid to Massachusetts from the sale of his membership interest in a limited liability company (LLC) doing business in...more

McDermott Will & Emery

Is California Picking the Pockets of Other States?

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n Matter of Body Wise International LLC (OTA Case No. 19125567; 2022 – OTA – 340P), a California-based retailer collected amounts designated as “tax” related to jurisdictions where it was not registered to collect tax. The...more

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