Taxation
Ca. Tax Lawyer VOLUME 34, 2025 ANNUAL ISSUE
Content
- 2024-2025 California Lawyers Association Tax Section Executive Committee
- 2025 Annual Award Winners
- By the Tax Section Members
- California's Anti-ing Trust Statute Comes With Strange Drafting Choices, Planning Opportunities, Landmines, and Apparent Errors
- Ctl Prize For Excellence In Writing
- Editors' Note: a New Way Forward
- From the Chief Counsels
- Government Contributions To Capital May Still Qualify For Exclusion From State Income Tax
- High Liability
- Inside This Issue
- Local Tax Sharing Agreements: a Constitutional Critique
- Message From the Chair
- Minutes From the 2025 Meeting of Eagle Lodge West
- Rational Basis or Broad Discretion: Legal Standards Governing Cdtfa Interpretations
- Table of Contents
- Managing Ftb Audits of International Taxpayers
MANAGING FTB AUDITS OF INTERNATIONAL TAXPAYERS
AUTHOR1
Philip Wolf
I. OVERVIEW
California is the fourth largest economy in the world2 and it is also the state with the highest income tax rate.3 Given these figures, it is not surprising that California is home to the second largest taxing agency in the nation (after the IRS) known as the California Franchise Tax Board.4 With over 6,200 employees5 the FTB is responsible for collecting the state’s personal and corporate income taxes6 from its headquarters in Sacramento as well as its satellite offices in Los Angeles, Oakland, San Diego, Santa Ana,7 Chicago,8 Houston,9 and New York.10 California also boasts the largest immigrant population in the U.S.,11 and it is a major hub for international business and trade. This global connectivity can impact the reach of the FTB, as many international taxpayers living, working, or doing business in California or receiving California-source income may face unique tax obligations.