John Ormonde

1 month ago | jdsupra.com | Michele Borens |Jeffrey Friedman |John Ormonde

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. (See our prior coverage here.) Proposition M changed the allocation and apportionment rules for most industries, generally requiring that three quarters of a taxpayer’s total receipts are allocated to the city on a market basis and one quarter are apportioned to the city using a payroll factor.

Jun 11, 2024 | jdsupra.com | Jeffrey Friedman |Timothy A. Gustafson |John Ormonde

California legislators released bill language addressing Governor Gavin Newsom’s “May Revise” to the state budget that includes the Governor’s so-called “apportionment fix.” If enacted, Assembly Bill 167 and Senate Bill 167 will suspend net operating losses for tax years beginning on or after January 1, 2024 and before January 1, 2027. Similarly, the legislation applies a $5,000,000 limit on most business tax credits for those same years.

May 16, 2024 | jdsupra.com | Jeffrey Friedman |Timothy A. Gustafson |John Ormonde

On May 14, California Governor Gavin Newsom released proposed trailer bill language for the so-called “apportionment fix” introduced in his “May Revise” to the state budget last week (see our prior Legal Alert here). Incredibly, the bill would retroactively codify a provision that would overturn two important apportionment cases that allowed taxpayers to include receipts in the sales factor even if the related income was not included in the tax base.

Feb 15, 2024 | lexblog.com | Maria Todorova |Charles Capouet |John Ormonde

A California appellate court held that Proposition 39, which mandated single-sales factor apportionment, did not violate the single-subject rule. In 2012, California voters enacted Proposition 39, which established a program to promote the creation of clean energy jobs. It funded the program by eliminating the option for taxpayers to apportion its California tax based on a three-factor apportionment formula, requiring instead single-sales factor apportionment.

Jan 19, 2024 | lexblog.com | Jeffrey Friedman |Daniel Schlueter |John Ormonde |David Patterson

We are eager to share our summary of SALT highlights from the past year, which was recently published in Tax Notes State. 2023 was an eventful year, and our Most Interesting State Tax (MIST) developments contain a mix of cases covering income tax, sales tax, and procedural issues. With numerous states grappling with similar issues that grabbed our attention in 2023, what MIST developments can we expect in 2024 and beyond? The anticipation is killing us. Read the full article here.