The purpose of this Quarterly California Tax Legislative Update is to provide our clients and prospective clients with timely and meaningful updates that affect both their personal income and business taxes.

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:

  • 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