On June 16, 2025, the Senate Finance Committee released a draft package that includes a major provision aimed at curbing the use of state pass-through entity taxes (PTETs) to bypass the federal $10,000 cap on state and local...more
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
10/31/2023
/ Administrative Hearings ,
Corporate Restructuring ,
Franchise Tax Board ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Non-Residents ,
Pass-Through Entities ,
Residency Status ,
S-Corporation ,
Sale of Assets ,
State Taxes ,
Subsidiaries
Nonresidents of California generally are not taxed by California on gain resulting from the sale of partnership interests. Under new guidance issued by the California Franchise Tax Board ("FTB") nonresidents can now...more
California has revised its existing SALT cap work-around to address and liberalize several of the significant limitations on the work-around that we discussed in our prior alert.
On February 9, Governor Gavin Newsom signed...more