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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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Insight

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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Insight

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.

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