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25 lip 2024 · The legal theory in the decision below seems to be that all gross receipts paid to any individual in exchange for his or her labor performed anywhere in the United States of America necessarily constitute income derived from a federally taxable source; thus, according to the California Court of Appeal, all such gross receipts necessarily constit...
Because California law incorporates the provisions of IRC section 6662, we also apply the Treasury Regulations promulgated thereunder, as required by R&TC section 17024.5(d), which provides as follows:
Franchise Tax Board (FTB) appeals from a summary judgment order holding (1) a trust’s income, even if entirely derived from California sources, is only taxable under residence-based taxation; and (2) the sole beneficiary of the Paula Trust was a contingent beneficiary.
26 lip 2018 · In general, a trust's entire taxable income is subject to tax in California "if the fiduciary or beneficiary (other than a beneficiary whose interest in such trust is contingent) is a resident" of California. (Cal. Rev. & Tax. Code §17742(a)).
7 lip 2020 · The California Court of Appeals held that the state imposes tax on the entire amount of trust income derived from California sources regardless of the residency of the trust’s fiduciaries. The taxpayer is reportedly petitioning the California Supreme Court for review.
9 sty 2024 · 2 BROOKS v. TREASURY Pamela Brooks was removed from her position as a Tax Compliance Officer with the Department of the Treasury following the agency’s determination that she had willfully understated her tax liabilityfederal for tax years 2005 through 2007. Ms. Brooks appealed the agency’s removal decision to the Merit Systems Protection ...
Reviewing the trial court’s ruling de novo, the Court held that a trust’s California source income is always taxable because: (1) a trust computes its taxable income in the same manner as an individual; (2) the taxable income of an individual (whether a resident or nonresident) always includes California source income; and (3) since ...
