Tax Law

Recent Posts

Tiny Interest + Big Property = California Nexus: Office of Tax Appeals Determines Minority LLC Interest Creates Taxable Nexus
Posted on 16 Sep 2020 by Eversheds Sutherland LLP

On July 7, 2020, the California Office of Tax Appeals (OTA) held that a foreign LLC was subject to the state’s $800 LLC tax because it held a 0.7830849% ownership interest in an LLC that owned property in San Diego. In addition to a more traditional nexus... Read More

Podcast: Washington B&O and California LLC Tax Developments
Posted on 8 Apr 2020 by Eversheds Sutherland LLP

This podcast discusses a recent Washington B&O decision and a recent California OTA decision concerning: The WA B&O taxation of services conducted out of state for in state customers The application of the CA LLC tax to a business that ceased... Read More

It’s None of Your Business: California Office of Tax Appeals Rejects FTB’s Broad Test for Doing Business
Posted on 19 Sep 2019 by Eversheds Sutherland LLP

The California Office of Tax Appeals (OTA) reversed the Franchise Tax Board’s (FTB) determination that an out-of-state limited liability company (LLC) had taxable nexus with California solely because it held an ownership interest in an LLC operating in... Read More