Kyle O. Sollie

Kyle O. Sollie

Reed Smith

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FTB to Clean Up Deferred Intercompany Stock Account Regulation

On July 25, the FTB held a public hearing on its proposed revisions to its regulation on intercompany transactions. The changes attempt to fix issues with the current rules governing Deferred Intercompany Stock Accounts...more

8/2/2013 - Corporate Contributions Franchise Tax Board Liquidation Mergers Proposed Regulation Stock Options

California’s Attempt to Retroactively Tax its Residents

In Cutler v. Franchise Tax Board, a case litigated by Reed Smith, a California Court of Appeal held that the California property and payroll requirements of California’s Qualified Small Business Stock provisions were invalid....more

2/12/2013 - Capital Gains Commerce Clause Cutler v Franchise Tax Board Franchise Tax Board Investors Qualified Small Business Stock Retroactive Application Retroactive Taxes Startups Tax Deferral

Microsoft Court Holds Right to Replicate Software Is an Intangible Property Right for Purposes of California’s Sales Factor...

Earlier this week, the California Court of Appeal, First District, held that the right to replicate and install software is an intangible property right for sales-factor sourcing purposes. Thus, for the years at issue, the...more

12/28/2012 - Franchise Tax Board Intangible Property License Agreements Microsoft Right to Replicate Royalties Software Tangible Property

California’s Proposition 39: Not-so-Mandatory Single Sales Factor

On November 6, California voters passed Proposition 39, which changes the state’s default apportionment to a single sales factor method. Additionally, Proposition 39 adopted a mandatory market-sourcing method for sourcing...more

11/14/2012 - Franchise Tax Board Gillette v Franchise Tax Board Multistate Tax Compact Proposition 39 Sales Factor

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