State And Local Thinking - February 2016

Tax professionals

California clarifies post-apportioned excluded cancellation-of-debt income used to reduce tax attributes
The California Franchise Tax Board has issued a technical advice memorandum addressing the reduction of certain tax attributes in instances when cancellation-of-debt-income (CODI) is excluded from gross income for California purposes. The guidance clarifies that post-apportioned, rather than pre-apportioned, excluded CODI should be used to reduce the tax attributes. Read the SALT Alert.

Oregon Tax Court finds taxpayer properly treated gain from stock sale and income from holding company as nonbusiness income
The Oregon Tax Court recently ruled that gain realized from the sale of a subsidiary's stock and income from a subsidiary holding company were properly characterized as nonbusiness income not subject to apportionment. Read the SALT Alert.