In a significant development for nonresident investors and private equity structures, the California Office of Tax Appeals (OTA) held that gain attributable to IRC section 751(a) “hot assets,” such as unrealized receivables and inventory items, remain part of the sale of a partnership interest. As the sale of an intangible interest, the sale of partnership
In GeTtin’ SALTy Episode 85, Nikki Dobay and Madeline Orlando discuss recent litigation involving state packaging extended producer responsibility laws and the potential implications for businesses subject to emerging EPR programs.
In GeTtin’ SALTy Episode 84, Nikki Dobay and Samantha Trencs discuss California Senate Bill 122, its expansion of sales tax to certain software and digital products, and related compliance considerations for businesses.
California’s CDTFA addressed stakeholder questions on proposed SB 122 regulations, including software and SaaS tax sourcing, MPU rules, contract transitions, and compliance ahead of the Jan. 1, 2027, effective date.
Continue Reading CDTFA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
In a pending precedential decision, the California Office of Tax Appeals held that gain from the sale of a beverage distribution division was not apportionable to California because the division was not part of a unitary business.
Continue Reading California Office of Tax Appeals Rejects Unitary Business Treatment for Gain from Sale of Company Division
On July 21, 2026, the California Department of Tax and Fee Administration (CDTFA) held its first implementation workshop meeting regarding Senate Bill 122 (SB 122), which extends California’s sales and use tax to digital software and software-as-a-service (SaaS) effective Jan. 1, 2027.
California’s tax landscape is shifting fast. This episode breaks down Governor Newsom’s newly signed budget, including a SaaS sales tax and credit limitations, alongside the ballot measures California voters will face in 2026 – from a proposed billionaire wealth tax to a personal income tax surcharge extension.
A California budget trailer bill would extend sales tax to software and SaaS and adjust business credit limits, with potential implications for tax planning and compliance.
Two tax measures aimed at addressing transit funding shortfalls in San Francisco and the surrounding region have gathered enough signatures to potentially qualify for the November 3, 2026, ballot. Property owners, commercial tenants, and consumers across five Bay Area counties may wish to monitor developments as certification proceeds and final ballot language takes shape.
Continue Reading 2 Tax Measures, 1 Ballot: San Francisco Parcel Tax, Regional Sales Tax Move Forward
In this episode of the GeTtin’ SALTy podcast, host Nikki Dobay is joined by Greenberg Traurig colleagues Brad Marsh and Jennifer Vincent to discuss a significant recent victory in the California Court of Appeal – First Appellate District: Xavier Garcia-Rojas v. Franchise Tax Board.
The case involved a Texas-based radiologist who performed all of