Taxation

CALIFORNIA LAWYERS ASSOCIATION TAXATION SECTION 2025 SACRAMENTO DELEGATION PAPER This proposal was prepared by Erica Love, Principal in the Sales and Use Tax Practice of Ryan, LLC, and Gina Rodriquez, Principal in the Advocacy Services Practice of Ryan, LLC. Contact Information: Erica Love Ryan, LLC 13155 Noel Rd. Ste 100Dallas, TX 75240(279)-600-3261 Gina Rodriquez Ryan, LLC500 Capitol Mall Ste. 2080Sacramento, CA 95814(972)-934-0022 Executive Summary A direct-payment permit is an authorization from a state tax agency that allows a qualified business… Read more

Dividends paid by captive insurance companies are eligible for an 85 percent dividend received deduction (“DRD”) for qualified dividend amounts. What constitutes a qualified dividend is determined by the five-year average ratio of third-party premiums written by the captive insurance company to its overall profit. Read more

This proposal recommends amending California Revenue and Taxation Code (“Rev. & Tax. Code”) Section 1603 (“Section 1603”) to establish a uniform assessment appeal filing deadline of November 30 for all 58 counties. Read more

This proposal was prepared by Gina Rodriquez, Principal in the Advocacy Services Practice of Ryan, LLC.[1] Contact Information: Gina Rodriquez Ryan, LLC500 Capitol Mall, Ste. 2080Sacramento, CA 95814(279) 600-3261 Executive Summary To ensure taxpayers have equal access to administrative appeal rights, California law and California Code of Regulations, title 18, Section 30103(b) (“Reg. 30103(b)”) should be amended to provide taxpayers with unresolved refund claims at the California Department of Tax and Fee Administration (“CDTFA”) with the same rights granted to… Read more

This paper examines the statutory and constitutional limitations on California’s authority to collect delinquent income-tax liabilities under Revenue and Taxation Code (“R&TC”) section 19255 (“19255”). The statute, enacted through Assembly Bill 911 (2006), was intended to impose a fixed twenty-year limit on the Franchise Tax Board’s (“FTB”) power to collect taxes after they become due and payable. Read more

By Frank E. Medina, Reed Smith LLP and Saba S. Shatara, Reed Smith LLP[1] Introduction California’s current audit notice procedures present significant challenges for taxpayers and the state alike. When taxpayers do not receive or inadvertently miss audit determination notices from state tax agencies such as the Franchise Tax Board (FTB) or the California Department of Tax and Fee Administration (CDTFA) they are often left without a meaningful administrative avenue to dispute the result of assessments. In these situations, taxpayers… Read more

Currently, the California Franchise Tax Board (“FTB”) does not provide a mechanism for taxpayers to dispute the merits of an assessed tax liability once a Notice of Proposed Assessment becomes final and before full payment. This forces taxpayers into a “pay to play” situation, requiring full payment before pursuing a refund claim, even when the liability itself is disputed. Read more

If you’re a tax attorney, CPA, or financial professional, California Lawyers Association’s (CLA) Annual State and Local Tax (SALT) Committee Meeting is designed specifically for you. Conducted by CLA’s Taxation Section, the two-hour educational event is being held on July 23, 2025. Participants may attend in person at the California Franchise Tax Board in Sacramento, or virtually, and earn 2.0 hours of MCLE/CPE in tax law legal specialization. Registration for the meeting, and education credits valued at nearly $300, are being provided at no cost to participants. Read more

California Lawyers Association’s (CLA) Taxation Section once again brought legal expertise to the forefront of federal tax discussions during its annual Delegation to Washington, D.C. this spring. Among the critical topics raised was a proposal to improve the IRS’s filing compliance procedure, just one of several impactful issues on the agenda. Read more

You're invited to the SALT Tax Annual Meeting in Sacramento! Read more