In the October 2023 edition of Spidell’s California Taxletter, Eversheds Sutherland Senior Counsel Eric Coffill shares six tips for settling tax matters with the FTB and theCDTFA.
Read the full article here.
Tax
An interview with California FTB Deputy Chief Counsel Shane Hofeling
By Eric Coffill
In this installment of Across State Lines in Tax Notes State, Eversheds Sutherland Senior Counsel Eric Coffill interviews Shane Hofeling, deputy chief counsel and director of the California Franchise Tax Board’s Technical Resources Bureau.
Read the full article here.
Shifting sands: Interest payments at issue in the latest installment of Maryland’s Wynne litigation
By Eric Coffill
In a recent unreported decision, the Maryland Appellate Court held that taxpayers were not entitled to a 13 percent interest rate on a judgement after the legislature lowered the state’s refund interest rate during the pendency of the taxpayers’ appeal.
The taxpayers successfully challenged the limits that Maryland state law placed on the tax credit for income taxes paid to…
POAs & the FTB: Tips & best practices for submitting a Power of Attorney
By Eric Coffill
In this article originally published by CalCPA in the January/February issue of California CPA, Eversheds Sutherland Senior Counsel Eric Coffill provides helpful tips for having a Power of Attorney (POA) submission to California’s Franchise Tax Board accepted the first time and for anticipating problems in using the POA.
Read the full article here.
5 proof of domicile takeaways from Calif. Tax Appeals ruling
By Eric Coffill
A recent significant precedential and unanimous decision by the California Office of Tax Appeals, Matter of the Appeal of Beckwith, provided more guidance on how to determine California domicile and residency for state personal income tax purposes.
In his article for Law360, Eversheds Sutherland Senior Counsel Eric Coffill provides five domicile takeaways and lessons learned from Beckwith.
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Valid check-the-box election: California resident entitled to a stepped-up basis
By Eric Coffill
On August 31, 2022, the California Office of Tax Appeals (“OTA”), in the Matter of the Appeal of B. Housman and B. Pena, held that an Australian software company holder, Housman, and his wife are California residents and Housman is entitled to a stepped-up basis as a result of a valid check-the-box election to be classified as a partnership for…
An interview with BOE Executive Director Yvette M. Stowers
By Eric Coffill
In his latest installment of Across State Lines for Tax Notes State, Eversheds Sutherland Senior Counsel Eric Coffill interviews the executive director of the California State Board of Equalization, Yvette M. Stowers.
Read the full article here.
State income taxation of nonresident equity-based compensation
By Eric Coffill
The increase in people who work remotely means some financial planners may need to reassess clients’ income sources to avoid a tax surprise.
In his article for Journal of Financial Planning, Eversheds Sutherland Senior Counsel Eric Coffill examines key issues related to the state income taxation of nonresident equity-based compensation and how to avoid potential pitfalls.
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A bridge too far: Ohio Court of Common Pleas finds convenience rule unconstitutional
By Eric Coffill
On September 26, 2022, the Ohio Court of Common Pleas in Morsy v. Dumas, held that Cleveland’s municipal income tax on remote workers was unconstitutional on an “as applied” basis. The taxpayer lived in Pennsylvania and was employed by a company located in Cleveland, Ohio.
Prior to the COVID-19 pandemic, Morsy would stay in Cleveland Monday through Friday returning home…
Calif. Tax Board nonresident asset ruling raises new issues
By Eric Coffill
Earlier this month, the California Franchise Tax Board released Legal Ruling 2022-02, regarding the sourcing of Internal Revenue Code Section 751(a) gain from the disposition of a nonresident individual’s partnership interest when the IRC Section 751 property is located in California.
In this article for Law360, Eversheds Sutherland Senior Counsel Eric Coffill discusses the nonresident asset ruling and its…