The terms "Private Placement Life Insurance" or "Private Placement Annuity", both referred to here as "PPLI", refer to policies designed to accomplish specific purposes for the policy owner. PPLI is usually issued by foreign...more
On January 8, 2013, we published a newsletter (a copy of which can be found here) detailing the Franchise Tax Board's ("FTB") questionable legal and policy decision to begin collecting on a retroactive basis approximately...more
A closer look at federal constitutional case law would seem to indicate that the State of California may not find it so easy to seek refunds plus interest after all....more
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
The California Franchise Tax Board (FTB) recently issued FTB Notice 2012-03, stating that the FTB will disallow the exclusion or deferral of gain under California's qualified small business stock (QSBS) statute for all tax...more
On December 21, 2012, the Franchise Tax Board ("FTB") released Notice 2012-03 (the "FTB Notice"), which notice outlines the procedures the FTB will apply in response to the Court of Appeal's recent decision in Cutler v....more
A court of appeal recently found unconstitutional a Revenue and Taxation Code provision that allows a taxpayer to defer capital gains when he or she sells stock in a qualified small business if the taxpayer uses the gain to...more
Article presents a brief overview of the Small Business Jobs Act signed into law by the President on September 27, 2010....more
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