In the pre-Facebook era, the word “like” was primarily a verb (and an interjection sprinkled throughout valley girls’ conversations). Although you could have likes and dislikes in the sense of preferences, you could not give...more
Hotels are one of the most misunderstood properties when valued by local assessors for property tax purposes. A hotel’s enterprise activity is comprised of tangible property, in the form of real estate and personal property,...more
As businesses move away from paper documents, courts are poised to broaden ‘conversion’ definition.
The fundamental shift for businesses in the past 15 years from paper documents to computer data has forced the courts...more
Code §2501(a)(2) provides that, except as to certain expatriates, U.S. gift taxes do not apply to the transfer of intangible property by a nonresident not a citizen of the United States. This exemption is big enough to drive...more
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
On December 18, 2012, the California Court of Appeal ruled that receipts from the right to replicate software are sourced as sales “other than tangible personal property.” In reversing the trial court, the Court of Appeal...more
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