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
- Managing Ftb Audits of International Taxpayers
- Message From the Chair
- Minutes From the 2025 Meeting of Eagle Lodge West
- Table of Contents
- Rational Basis or Broad Discretion: Legal Standards Governing Cdtfa Interpretations
RATIONAL BASIS OR BROAD DISCRETION: LEGAL STANDARDS GOVERNING CDTFA INTERPRETATIONS
AUTHORS1
Aeron Tisdale
Antonio Yaldo
Administrative agencies play a crucial role in interpreting and enforcing statutory provisions through their regulatory authority. Courts often grapple with the appropriate level of deference to afford these agency regulations, balancing the principles of separation of powers with the need for efficient governance. The following examines how courts apply dueling standards of review, particularly in the context of the California Department of Tax and Fee Administration ("CDTFA") and its rulemaking authority.