Taxation

Rami M. Khoury and Daniel W. Soto, from the Law Offices of A. Lavar Taylor LLP, are presenting an overview relating to innocent spouse relief from Internal Revenue Service liabilities. The presentation includes, but is not limited to, an overview of the current law and procedures regarding IRS innocent spouse relief, tips for tax practitioners representing clients seeking relief from joint IRS tax liabilities, and other issues related to IRS innocent spouse relief claims and litigation. While the presentation will mostly focus on relief from joint and several liabilities under IRC Section 6015, the presenters will also cover relief from joint and several liabilities on Married Filing Separately returns pursuant to IRC section 66(c). Read more

For over 30 years, the Taxation Section (first as part of the California Bar Association, and now part of the California Lawyers Association) has sent an annual delegation to bring California tax lawyers and their ideas to Washington, D.C. Just prior to the American Bar Association Tax Section Meeting held in Washington, D.C., a group of selected delegation members from the Taxation Section of the California Lawyers Section... Read more

The speakers will discuss recent developments in California income tax apportionment and sourcing law, including recent Office of Tax Appeals decisions, guidance from the Franchise Tax Board and the 25136-2 regulation process. Read more

Welcome to the 2021 Annual Income Tax Seminar! Earn 4.0 Hours of MCLE, which includes Legal Specialization in Taxation Law. Read more

In this program, William Gorrod, will address recent state and local tax legislation and cases, and will provide an opportunity for discussion of important state and local tax issues impacting companies. Read more

This paper was researched and written by Executive Director Elisabeth Sperow and student accountants Tia Bentivegna, Rachel Farris, Andris Germanis, Nathan Nguyen, Garrett Rexford, and Ridge Schorling (the “team”) of the Cal Poly Low Income Taxpayer Clinic located at California Polytechnic State University, San Luis Obispo. The authors wish to thank Duane Henning, Beth Hodess, and Annette Nellen, for their valuable assistance as reviewers for this paper. Read more

The purpose of this paper is to examine the way in which the net income (including capital gains) of a domestic trust is taxed for federal income tax purposes during the lifetime of the U.S. resident settlor or grantor of the trust, and to recommend a revision of the so-called “grantor trust rules” in Subpart E of Subchapter J of the Federal Income Tax Law (IRC Sections 671 through 679) and the corresponding provisions of the estate and gift tax rules relating to irrevocable transfers in trust (IRC Sections 2035 – 2038 and 2511). Read more

In 2009, foreclosure threatened millions of American homeowners in what was the biggest housing crisis since the Great Depression. Although the climate of bankruptcies and mortgage foreclosures improved during much of the following decade, the current COVID-19 pandemic has thrust many homeowners back into a state of financial uncertainty. Read more

This proposal was prepared by Annette Nellen, member of the Tax Policy, Practice and Legislation Committee and Tax Executive Committee of the Taxation Section of the California Lawyers Association.1 The author thanks reviewers Elisabeth Sperow and Beth Hodess for their helpful comments Read more

International employees who are United States (US) non-residents routinely travel to the US on business trips. These international business travelers (IBTs) often are not eligible for a US Social Security number (SSN) because they do not have a visa type that permits them to apply. Read more