In Matter of Gatewood Corp, OTA Case No. 19105425 (July 3, 2024), the California Office of Tax Appeals (âOTAâ) concluded that Gatewood Corporationâs (âGatewoodâ) transfer of stock did not entitle it to a $10 million deduction because the transaction lacked economic substance and was for the purpose of tax avoidance, resulting in $831,398 additional tax. The California Franchise Tax Board (âFTBâ) conceded a $332,559 non-economic substance transaction (âNESTâ) penalty that it had originally imposed. In…
Latest Posts
- California Continues to Challenge Economic Substance and Business Purpose
- Nebraska Supreme Court Affirms Denial of âDeemed Dividendâ Deduction For IRC §965 Income
- California Data Extraction Bill Advances in the Senate
- Vermont to Impose Sales And Use Tax on Remotely Accessed Software Sales
- Qualified New York Manufacturer Wins at New York Division of Tax Appeals: Use of Third-Party Subcontractor Did Not Affect Eligibility for State Franchise Tax Reduced Rate
- The Illinois Appellate Court Boots False Claims Suit Against Foreign Tailor
- Plot Twist: New York Legislation Would Give the Commissioner of Taxation and Finance Appeal Rights Following Certain Adverse Tribunal Decisions
- States Focus on Taxing High Net Worth Individuals
Recent Posts
The one-time IRC §965 income inclusion for untaxed foreign earnings generated by a controlled foreign corporation (âCFCâ) is…
The California legislature is proposing a 7.25% tax on âdata extraction transactions in the stateâ through Senate Bill (âSBâ)…
Vermont will impose its sales and use tax on sales of remotely accessed software effective July 1, 2024…
The New York Division of Tax Appeals recently ruled in favor of a taxpayer, E. & J. Gallo…
The Illinois False Claims Act (“IFCA”) has been perpetually abused by parasitic litigants seeking to force businesses into…
As part of the New York Budget Legislation (âS.B. 4009 / A.B. 3009â), Â the Commissioner of the New…