2025 California All-Tax Conference

State and Local Tax: Building Your Foundation for Success. This workshop is designed specifically for law students and younger tax attorneys looking to gain a practical understanding of state and local tax. We’ll explore key compliance issues, emerging trends, and strategies to be an effective SALT practitioner – equipping you with the knowledge to confidently tackle real-world challenges. Get ready to move beyond theory and dive into the ‘nuts and bolts’ that drive SALT practice.

Seeing Estate Plans Become Actions: For law students and younger tax attorneys, the trust and estate administration resulting from a client’s death can feel like a world of complex rules. This workshop cuts through the theory and gets down to the practical ‘nuts and bolts.’ Learn from our expert panel about the many steps one must follow, along with the important tax and other elections one has, in handling the death of a decedent residing in California.

This foundational panel is designed for law students and early-career tax attorneys seeking to build a strong understanding of federal tax litigation and procedural practice. The bootcamp will walk through the lifecycle of a federal tax controversy—from audit through appeals, and into litigation—highlighting key procedural rules, strategic considerations, and practical insights at each stage. Topics will include navigating IRS examinations, responding to notices and summonses, pursuing administrative remedies, and litigating in the U.S. Tax Court, District Courts, and the Court of Federal Claims. Attendees will also gain exposure to critical procedural doctrines such as jurisdictional limitations, statute of limitations issues, collection due process, and refund litigation. Whether you’re exploring a career in tax or sharpening your procedural toolkit, this workshop offers an engaging and accessible entry point into the world of federal tax controversy.

Join this panel for a discussion on the updates, policies, and fundamental principles of the California sales factor. The panel will discuss and analyze the impacts of OTA’s Microsoft decision and CRTC Section 25128.9 and how other states address the vexxing issue of gross receipts in the sale factor.

Our panel will review select recent developments in legislation (including the One Big Beautiful Bill Act), guidance, and controversies affecting estate, gift, GST, income, and other taxes relevant to private client practitioners.

The Bipartisan Budget Act was passed in 2015. Learn where we are after 10 years. What have we learned, what works, and what can be impoved. Turn on screen reader support To enable screen reader support, press ⌘+Option+Z To learn about keyboard shortcuts, press ⌘slashThe Bipartisan Budget Act was passed in 2015. Learn where we are after 10 years. What have we learned, what works, and what can be impoved.

Join this panel for a lively and informative discussion on the developing landscape of Special Taxes and Fees administered by the CDTFA, including the California Firearm, Ammunition, and Firearm Precursor Part Excise Tax (CFET), the Cannabis Excise Tax, and other special taxes and fees such as the Marine Invasive Species Fee.

After years of waiting, we finally know how to apply IRC Section 2801, providing a special transfer tax applicable to transferees of inter vivios and testamentary gifts from covered expatriates. Our panelists will describe these rules and how to plan for them for your clients.

Everyone wants to be a zealous advocate for their client. Doing so, doesn’t mean you have to be unprofessional toward opposing counsel. California attorneys take a civility oath, and can be disciplined for a lack of civility. Attorneys are also required to have 1 hour of MCLE on civility. In the world of tax practice, where the government is almost always on the other side, being civil isn’t just a courtesy, your reputation may depend it on. Your behavior can have an impact on your client. Don’t be a jerk.

Join panelists from the California Office of Tax Appeals and private practice for an informative and interactive session providing the latest updates from the state’s independent tax appeals agency. This session will feature a comprehensive year-in-review presentation highlighting key developments, opinions, and other updates from the last year. Attendees will also have the opportunity to engage directly with OTA staff during a live Q&A session.

How did the Big Beautiful Bill affect charities? How do we deal with its limitations on charitable deductions? We will discuss these and other recent developments affecting the tax and practical aspects of making contributions and grants to charities.

Some of the foundational rules we thought we knew are now being contested, to varying degrees. Learn why what we thought we knew might not be true and how you can think outside the box to help your client. The failure to do so may even be considered malpractice in some situations.

This panel will provide an overview of major tax legislation enacted in California in 2025, including updates affecting income, sales and use, property, and excise taxes. Panelists will highlight significant statutory changes, emerging trends, and their practical implications for taxpayers and practitioners.

What role does life insurance play in the post-OBBBA tax environment, where $15M+ estates are the minimum wager to even face estate taxes? Our panel will answer this question, looking not only to the effective estate tax planning still achievable with life insurance, but also to income tax savings that life insurance can achieve.

A panel of Tax Court judges and practitioners discuss the hottest topics in Tax Court Litigation. This annual panel is not to be missed.

This panel will cover common FTB and CDTFA audit methods for various types of businesses, helpful information to provide for audit, and documents auditors may request to complete the audit.

In estate and gift tax audits, perhaps the single likeliest point of contention between the IRS and taxpayers is the valuation of hard-to-value assets. Our panel, replete with a Tax Court judge and experienced practitioners, will walk you through these contests, how valuations work, and what kind of valuations are persuasive in litigation.

Mental health challenges can’t always be seen, but may be hiding in plain sight if you know what to look for. Many of our clients struggle with their mental health and we never ask or think it might help their case.

This panel will provide an overview of recent developments in SALT litigation across the country. The session will highlight significant court decisions, administrative rulings, and constitutional challenges shaping the SALT landscape. Panelists will discuss hot-button issues such as apportionment and sourcing disputes, challenges to retroactive tax legislation, nexus and P.L. 86-272 controversies, and the expanding reach of state tax authorities in the digital economy. The panel will also examine procedural developments, including standing and jurisdictional hurdles in state tax litigation. (SALT)

The California fiduciary income tax is full of uncertainties. The residency of trusts depends on the residency of noncontingent beneficiaries and fiduciaries–but who counts as such, and do they count as such as to the whole trust or only that portion as to which they have an interest? How do you know when you’re making a distribution that triggers throwback tax, or if you’re distributing principal or current income? Can losses at the trust level reduce accumulated income for the throwback tax? Are there potential constitutional challenges to the law? Can we benefit from a “hybrid” state/federal trust? This panel will discuss these and other topics.

The OBBB is full of changes, but not all of them impact the world of tax controversy. Learn what changes are ones you should know about and how to properly advise your clients.

Recent California case law has determined that certain sales of interests in LLCs should be sourced at least partially, if not entirely, to California, potentially impacting the Other State Tax Credit treatment, particularly when the other state sources these interests differently. This discussion including panelists from FTB and private practice will cover the law impacting sourcing nonresident income from intangible property and the corresponding impact on the Other State Tax Credit. Additionally the panel will address emerging issues related to the Other State Tax Credit, including new precedent and how the credit is impacted by the Passthrough Entity Tax. Through the panel’s presentation and Q&A, this session will focus on how professionals can best prepare for this developing area of the law.

California’s property tax reassessment rules can be confusing, and full of traps for the unwary. Layer in property-owning legal entities, trusts, special rules governing joint tenancies, and transfer taxes, and the puzzle gets even more complicated. Even worse, some jurisdictions might claim that gifts or inheritances of legal entity interests trigger documentary transfer tax. This panel will explore the intersection between estate planning, Prop. 13, and documentary transfer tax.

Tax practice is full of conflicts and pitfalls. Learn how to deftly navigate the minfield that is avoiding conflicts. You need to know who your client is, who is paying your fee, and when it’s best to walk away. Every practicitioner wants to attract business, but don’t let that get you in trouble.

Don’t miss this rare opportunity to hear directly from the Chief Counsels of the Board of Equalization, California Department of Tax and Fee Administration, Franchise Tax Board, and Office of Tax Appeals. Get the inside scoop on key developments from the past year and gain valuable insights into what’s on the horizon. Whether you’re looking to stay ahead of regulatory changes or deepen your understanding of California’s tax landscape, this session is a must-attend!

Owners of real estate and agricultural property are beset by tax complexity. Whether it’s determining how to balance estate taxes and basis step-up, whether to attempt to defer estate taxes or elect a lower value for certain properties, or how to take into account state and local taxes, these owners need our help. Join our panel to learn the issues of these taxpayers and how best to plan for them.

The current administration has emphasized immigration enforcement. The Department of Justice has listed Denaturalization as a priority. The number of US citizens and long-term residents expatriating continues to rise. The IRS is also now playing a role in cooperating with other areas of immigration law enforcement. Learn how these issues may impact your practice.