A California nonresident is taxable by California on income earned from sources in California. Where two or more commonly owned companies carry on a trade or business within and outside of California, the net income is allocated and apportioned between California and other states under the Uniform Division of Income for Tax Purposes Act (“UDITPA”). In Appeal […] Read More…
Hot off the press is the Tax Court’s decision in Paschall v. Commissioner, T.C. Memo. 2026-46, which is the first significant merits decision addressing whether proof-of-stake rewards are taxable when received. The Court held that Alvie and Patricia Paschall had unreported income from Cardano staking rewards credited to Mr. Paschall’s eToro account in 2021. Click […] Read More…
The California Office of Tax Appeals (OTA) recently published two precedential sales tax pending decisions that, in practical terms, answered questions regarding personal liability, penalties, and interest abatements for unpaid sales tax. Part I focused on the Appeal of Sundown Entertainment Group, Inc., 2026-OTA-225P. There, the OTA sustained a large sales tax determination after the […] Read More…
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