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G&G State Tax Group

G&G State Tax Group

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Edvin Givargis

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The watchlist

Public Law 86-272, Reinterpreted

California Sales Tax on SaaS

The SALT Cap and the PTET Election

The Proposition 40 Wealth Tax

Practice and Procedure

Practice and Procedure

Assessments and protests

Income and franchise procedure

Local and district taxes

Nexus and registration

Water's edge and international

Alabama Practice and Procedure

When Alabama recharacterizes a real estate sale as business income, what happens to nonresident composite tax?

Arizona Practice and Procedure

Does Arizona's transaction privilege tax exempt machinery and equipment used in manufacturing?

California Practice and Procedure

A company opens its first California office: which registrations and taxes follow?

Are California waiting time penalties deductible?

Are sales of mortgage notes included in California's sales factor at gross proceeds or net gain?

Are sales picked up at a California warehouse California sales for apportionment?

Can a taxpayer use the installment method for California but not for federal tax purposes?

Can a website defeat California throwback?

Can California tax a nonresident spouse's out-of-state wages through community property?

Can California's large corporate understatement penalty be waived?

Do sales reps in California create sales tax nexus below the Wayfair threshold?

Does a change in control of an entity trigger California documentary transfer tax?

Does a corporate limited partner in an investment fund apportion or allocate its California income?

Does a federal accounting method change automatically apply for California?

Does a foreign corporation with no California activity owe California's minimum tax?

Does a stopover in California trigger use tax on goods in transit?

Does California follow a federal check-the-box entity classification election?

Does California require withholding when a partnership distributes refinancing proceeds?

Does California tax income a foreign corporation excludes under IRC Section 883?

Does California tax stock options exercised after a move out of state?

Does filing an extension disqualify a taxpayer from California's voluntary disclosure program?

Does owning a disregarded LLC that operates in California give the owner nexus?

Does the billing address or the shipping address decide the California sales tax rate?

How are asset management fees sourced for California apportionment?

How are days counted in a California residency audit, and what evidence wins?

How are receipts from services performed at sea sourced for state tax purposes?

How do California manufacturers use the partial exemption and Cal Competes?

How does a combined group with both financial and general corporations apportion its income?

How does a company with no gross receipts apportion its California income?

How does a taxpayer petition the Franchise Tax Board for alternative apportionment?

How does a taxpayer protest a Notice of Proposed Assessment in California?

How does California pass-through withholding work for domestic nonresident owners?

How does California source a nonresident's compensation and fringe benefits?

How does California source carried interest when a partner changes residency?

How does California source receipts from services and intangibles?

How does California tax PFIC income when it does not conform to the federal PFIC rules?

How does California treat a Section 338(h)(10) election, and where does the gain land in the sales factor?

How does California treat IRC 367(d) deemed royalties in worldwide and water's edge years?

How does the FTB evaluate a claimed change of residency out of California?

Is a federally disregarded limited partnership subject to California's $800 annual tax?

Is a foreign student on a company-funded scholarship taxable in California?

Is a merger termination fee business income in California, and does it belong in the sales factor?

Is California withholding required on dividends paid to out-of-state owners?

Is SaaS taxable in California?

Is the California S corporation tax deductible on the shareholders' California returns?

What actually happens in an FTB residency audit, from first letter to protest?

What happens after an S corporation files a California refund claim?

What happens in a CDTFA sales tax audit of an out-of-state seller?

What happens in an EDD worker classification audit?

What happens in the first sixty days of an FTB business entity audit?

What happens to a California water's edge election when the group reorganizes?

What happens when California withholding credits do not match the K-1?

What makes a water's edge election valid when the return and the election disagree?

What must a seller do with over-collected California sales tax?

What property tax relief can a California wildfire victim claim?

What resale documentation survives a California sales tax audit?

What should be done when an FTB Notice of Tax Return Change is wrong?

When are dividends from an insurance company subsidiary deductible in California?

When do California's bright-line nexus thresholds make a passive investor a taxpayer?

When does a design studio owe California sales tax: concept or finished art?

When does a disregarded LLC file a short period California Form 568?

When does California throwback apply, and what makes a taxpayer taxable in another state?

When is a foreign corporation excluded from a California water's edge combined report?

When is a vessel exempt from California property tax, and does the sales tax exemption match?

Where does the dividends paid deduction go on a California REIT return?

Who decides a California tax appeal? The post-2017 landscape

Who is the payee for California withholding when distributions go to a disregarded entity?

Why is the county assessing property tax on leased port property?

Colorado Practice and Procedure

How does Colorado tax a REIT and its taxable REIT subsidiary?

Connecticut Practice and Procedure

Does Connecticut source a production company's receipts like any other service business?

Does it matter for Connecticut taxes whether real estate is held in an LP or an LLC?

Hawaii Practice and Procedure

Does Hawaii's general excise tax apply to work for the federal government?

Idaho Practice and Procedure

Does registering for Idaho sales tax also cover resort city and auditorium district local option taxes?

Illinois Practice and Procedure

Does a trust or a REIT owe Illinois replacement tax?

Multistate Practice and Procedure

Can a receivables company have nexus where it has no office?

Does Public Law 86-272 protection reach a state's minimum franchise tax?

Entering voluntary disclosure? What a state-rate-only exposure estimate misses

How do states apportion REMIC excess inclusion income?

How do states decide whether to withhold on a nonresident partner's sale gain?

How do states treat an S corporation's 338(h)(10) election?

Should a company protected by P.L. 86-272 still file state returns?

What did South Dakota v. Wayfair actually decide?

What does a revenue recognition change do to state apportionment and sales tax?

What does a second review of state tax returns look for, and when is it worth doing?

What happens in a multistate nexus study?

Where did economic nexus come from?

Which group member must file a state's combined corporate return?

Which sales rep activities break P.L. 86-272 protection?

Who taxes an opportunity zone deferred gain when the investor changes states before recognition?

Who withholds state income tax on a vessel crew's wages?

Whose employees are they when a professional employer organization runs payroll?

Whose physical presence counts as the company's?

Nevada Practice and Procedure

Does the Nevada real property transfer tax apply to a transfer between affiliated entities?

New Jersey Practice and Procedure

Does New Jersey charge sales tax on a commercial real property lease?

New York Practice and Procedure

Does a fund or investor owe New York City's Unincorporated Business Tax on trading income?

Does a single-member LLC owe New York City's Unincorporated Business Tax?

How are a broker-dealer's receipts sourced in New York when the business is a partnership?

How does New York count workdays when allocating a nonresident's wages?

How does New York decide someone actually left?

Is SaaS taxable in New York, and where is it used?

What happens in a New York sales tax audit of a software company?

When can a taxpayer use alternative apportionment in New York?

Ohio Practice and Procedure

When must an Ohio pass-through entity withhold for its investors, and who can be left out?

Oregon Practice and Procedure

Does a partnership that owns a single-member LLC doing business in Oregon have filing obligations there?

Does buying Oregon real estate reset the property tax assessment?

What taxes beyond property tax apply to a business operating in Portland?

Tennessee Practice and Procedure

How is the Tennessee franchise tax computed for an entity holding real estate in the state?

Texas Practice and Procedure

When does an out-of-state business owe Texas franchise tax with no Texas footprint?

Where is a Texas sale consummated for local sales tax purposes?

Utah Practice and Procedure

Does claiming Utah's primary residential exemption make someone a Utah resident?

What happens when a partnership underpays Utah withholding because its apportionment changed?

Washington Practice and Procedure

How does Washington tax a cryptocurrency mining or staking operation?

How does Washington tax commercial vessels?

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