The first quarter of 2014 was a relatively quiet time in California from a tax legislative perspective. The Franchise Tax Board ("FTB") upheld its position that pretty much all income in California should be treated as apportionable business income based on a Superior Court ruling that a merger termination fee is apportionable business income in California. The State finally dealt with the inability of companies to reduce or eliminate a Deferred Intercompany Stock Account ("DISA") by passing legislation allowing for the elimination or reduction of a DISA under certain circumstances. Finally, a new assembly bill attempts to once again redefine change of ownership for real property tax purposes.
This tax alert includes information on the following:
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Superior Court Rules that Termination Fee is Apportionable Business Income
- Amended Regulation Passed Allowing for the Reduction of a DISA
- New Assembly Bill Redefines Change of Ownership that Triggers Property Tax Reassessment
