1) New York State Final Corporate Tax Regs: A Sorites Paradox for NYC?
State Tax Notes, Volume 112, Number 9 May 13, 2024 · May 13, 2024
How New York City’s new business corporation tax regulations might look like, keeping in mind the city’s different regulations for different tax types, and New York state’s recently finalized corporate tax regs.
The article analyzes the differences between "Convincing" versus "Cogent;" NYC Admin Code sections 11-654.2(2)(d), 11-654.2(3)(b); and N.Y.C. R. section 11-65(e)(2).
2) New York City office-sharing agreements and commercial rent tax
The Tax Adviser (Volume 55, Number 5) p 32, May 2024 · Apr 30, 2024
A discussion on NYC Finance Letter Ruling (FLR) 22-5018, and business engaging in office-sharing agreements may be subject to the New York City's commercial rent tax (CRT)
3) Personal Income Tax: The Other State Tax Credit
The Tax Adviser (Volume 54, Number 5) p 19, May 2023 · May 1, 2023
Discussion about California's out of state tax credit, and ongoing litigation pertaining to Appeal of Mather (Appeal No. 18093787), and whether California allows a credit for NYC's Unincorporated Business Tax.
4) FTB Legal Ruling 2019-01: Which Came First, the Chicken or the Egg?
State Tax Notes, (Volume 107, pg. 329) · Jan 23, 2023
This article describes what procedural rights are attached with requesting a variance under Cal. Rev. & Tax Code section 25137 and examines California FTB Legal Ruling 2019-01 contradictions.
5) Legal Ruling 2021-01 — When the Tail Wags the Dog
State Tax Notes (Volume 105, Number 1), pg 7 · Jul 4, 2022
This article examines FTB Legal Ruling 2021-01, which addresses situations in which a passthrough entity serves as a holding entity of another passthrough entity. It also compares and contrasts FTB Legal Ruling 2014-01 and FTB Legal Ruling 2018-01.
6) California FTB Ruling 2018-01: Lipstick on a Piggy Bank and Financial
State Tax Notes, (Volume 96, number 12), p. 1451 · Jun 22, 2020
Analyzing principles of statutory construction in FTB Chief Counsel Ruling 2018-01, pertaining to Regulation section 23183
7) Dark Side of the Moon - Analyzing California's Space Regs
State Tax Notes, (Volume 90, number 9), p. 783 · Nov 26, 2018
An analysis of California's recently adopted space transportation regulations under Regulation section 25137-15
8) California’s Taxation of Sports Teams — Good Intentions Gone Awry
State Tax Notes, ( Volume 86, Number 3), p. 247 · Oct 16, 2017
An analysis of pro sports teams' California apportionment and allocation formulas for purposes of California Revenue and Taxation Code section 25141 (RTC section 25141).