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Insight

California: IRC section 338(g) Gain Must be Apportioned Using Target’s Factors

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.

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New Jersey: Division Issues Revised Guidance on Sourcing GILTI and FDII

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.

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Utah: Equitable Adjustment Prov. Do Not Apply to Avoid Double Taxation of Foreign Bus. Income

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.

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The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.