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Residency/domicile is a critical issue in a state-tax analysis because, as a general principle, a state taxes its own residents on all their income from whatever sources it is derived (typically with a credit mechanism for some or all tax paid to another state on that same income). However, regardless of residency and regardless of whether the individual has any

This installment of “Behind the Board,” which highlights the milestones, challenges, and lessons of Tax Notes State’s advisory board, focuses on Senior Counsel Eric Coffill.

Read more about Eric’s career and reflections here.

In a world and state already riddled with uncertainty, California holds a recall election. Through it all, however, taxes remain a constant.

On September 15, join Eversheds Sutherland attorneys Tim Gustafson and Eric Coffill as they cover key tax events that occurred in California during the first three quarters of 2021 and how the recall election may affect the state’s

A three-judge panel of California’s Office of Tax Appeals (“OTA”) issued a precedential decision ruling that taxpayers remained domiciled in and residents of California at the time they sold their aviation business despite renting an apartment in Nevada prior to purchasing a home in the same area.

At the time of the sale, the taxpayers were in the process of

California legislators have introduced a bill to impose a wealth tax on high-wealth residents and some nonresidents.In their article for Bloomberg Tax, Eversheds Sutherland attorneys Tim Gustafson and Eric Coffill provide an overview of the proposed wealth tax and its provisions, hypothetical tax calculations for various taxpayer scenarios, and a discussion of the bill’s relief mechanisms and enforcement provisions.

AB 71 was introduced earlier this year (see our prior coverage here) to provide additional state funding for homelessness programs, derived – in part – from increasing taxes on business income. In March, AB 71 was amended to eliminate steep corporate tax increases. The bill as amended, however, still would require corporate taxpayers that make a water’s-edge election to

2020 saw significant state and local tax activity in California.

In this webcast, Eversheds Sutherland attorneys Tim Gustafson and Eric Coffill look ahead into 2021 and what promises to be another unpredictable year in California tax legislation, administration and litigation.

View the presentation slides here.

The Delaware Superior Court granted summary judgment in favor of the taxpayer finding that the Division of Revenue’s limitation on net operating losses violated the state constitution’s uniformity clause and that the Division improperly limited the amount of separate company NOL the taxpayer could claim on its Delaware income tax return to the amount of its federal consolidated NOL deduction.

On December 17, 2020, a California Court of Appeal in the state’s Fifth Appellate District reversed a Fresno trial court decision, which held the California Constitution’s requirement that local taxes be approved by a supermajority vote applies to taxes imposed by voter initiative.  The Fifth District followed in the footsteps of the First Appellate District, which reached a similar conclusion