California OTA Catch-up

In this episode of GeTtin’ SALTy, host Nikki Dobay is joined by GT Shareholder Shail Shah for a discussion of some recent decisions released by the California Office of Tax Appeals (OTA). Shail provides an overview of what is likely the OTA's most significant case to date, in which the OTA ruled that a water’s-edge filing taxpayer was entitled to include 100 percent of certain dividend income under IRC 965 in its sales factor despite California allowing for a 75 percent dividends-received deduction. Shail also discusses his--and many others--surprise that this decision has initially been marked non-precedential and what could be done to change that.  Finally, Nikki and Shail discuss summer cocktails.  And, of course, Frankie has a few things to say during the conversation as well.