You are invited to attend the third installment of our new series on California Tax Issues. This recurring series will discuss specific topics in personal, corporate, and property taxation, as well as policy and administrative changes within the state and how they may impact your business. Our California team will provide insight on challenges to state policies and other unique strategies to help resolve tax controversies. 

Speakers: Andres Vallejo Priscilla Ayn Parrett

Event Type: Webinar

Start Date/Time:
15 March 2018, 2:00 PM EDT
End Date/Time:
15 March 2018, 2:30 PM EDT

The topic for this installment is: California combination without unity of ownership? Under California law (Cal. Rev. & Tax. Cd. § 25105), entities must have unity of ownership, as measured by a bright-line test (ownership of more than 50 percent of voting stock), before they can be combined. Despite this prerequisite to combination, the Franchise Tax Board (FTB) is advancing an argument that under another statute (Cal. Rev. & Tax. Cd. § 25102) the FTB can force combination between entities that do not meet the bright-line test for unity of ownership and, indeed, may not have common ownership at all. This webinar will discuss the FTB’s evolving position in this regard and explore strategies for dealing with this issue.

  • Background and history of the relevant statutes
  • Analysis of the FTB’s position
  • Strategies for dealing with audits and controversies