TWIST - August 26, 2019

The California Franchise Tax Board recently issued a chief counsel ruling concluding that gain recognized from an IRC § 338(g) election must be reported by the target entity on its final return and apportioned to California using its own apportionment factors.

Recently, the New Jersey Division of Taxation released a new technical bulletin, TB-92 issued August 22, 2019, addressing New Jersey’s treatment of FDII and GILTI.

The Utah Supreme Court recently reviewed a constitutional challenge to Utah’s individual income tax structure, as it applied to foreign and interstate business income of S corporation shareholders.