franchise tax board

Wayfair Strikes Again…Out of State Retailers Beware

According to a recently issued controversial Technical Advice Memorandum (“TAM”) issued by the Franchise Tax Board (“FTB”) the United States Supreme Court decision in South Dakota v. Wayfair, Inc., may have gutted the “mere solicitation” taxpayer protection under Public Law 86-272 (“PL 86-272”).

Out of State Partners Beware: Welcome to Taxifornia

Based on the Franchise Tax Board’s (“FTB”) recently issued legal ruling, nonresident partners who previously thought the sale of their partnership interests were treated as the sale of intangible property and excluded from California taxation under Cal. Rev. and Tax.