Roy E. Crawford
Subscribe to Roy E. Crawford's PostsRoy E. Crawford focuses his practice on corporate franchise and income taxation, personal income taxation, and sales and use taxation. He represents taxpayers in disputes and tax planning in many jurisdictions, with an emphasis in states that have adopted the Uniform Division of Income for Tax Purposes Act. Read Roy E. Crawford's full bio.
New California Office of Tax Appeals Discusses Emergency Regulations
By Roy E. Crawford on Nov 15, 2017
Posted In California, Income Tax, Procedure, Sales Tax
The New California Office of Tax Appeals (OTA) on November 6, 2017, held an interested parties meeting in Sacramento to discuss the contents of a draft of emergency regulations to guide both income tax appeals from the California Franchise Tax Board and sales and use tax appeals from the California Department of Tax and Fee...
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California’s New Office of Tax Appeals Issues Preliminary Draft of Procedural Rules that Is Silent on Discovery Matters
By Roy E. Crawford on Nov 1, 2017
Posted In California, Income Tax, Procedure, Sales Tax
As part of Governor Jerry Brown’s 2017 budget bill, the California State Board of Equalization (SBE) was stripped of its functions that had been authorized by statute, leaving principally property tax matters deriving from the state constitution. Sales and use tax and fee functions were moved to a newly created California Department of Tax and...
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California FTB Schedules Interested Parties Meeting on Short Notice to Discuss Issues in the Regulations on Sourcing Income from Services and Intangibles
By Roy E. Crawford on Jan 5, 2017
Posted In Allocation/Apportionment, California, Income Tax
The California Franchise Tax Board has scheduled an Interested Parties Meeting to discuss proposed changes to its apportionment regulations. Several years ago, when the statute called for sourcing receipts from services and intangibles at the location of income producing activity, based on cost of performance, the FTB, after a series on interested parties meetings, adopted new...
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California FTB to Discuss Apportionment of Combined Group Income
By Roy E. Crawford on Mar 24, 2016
Posted In Allocation/Apportionment, California, Income Tax, Unitary Business
The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for combined reporting groups with both financial and non-financial members. The Notice of Interested Parties meeting provides a description of the sourcing methods used in other...
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Recent Legislation in Virginia Retroactively Amending the Addback Statute Exacerbates a Potentially Unfair Law
By Roy E. Crawford on Jun 13, 2014
Posted In Allocation/Apportionment, Constitutional Issues, Income Tax, Virginia
Separate return state addback statutes, such as the Virginia addback statute, can overreach to produce an unfair and potentially unconstitutional overstatement of income assigned to the state. Recently Virginia amended its addback statute retroactively 10 years to taxable years beginning on or after January 1, 2004. The legislation is intended to codify an administrative interpretation...
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Does the Massachusetts Department of Revenue Still Believe SaaS is Subject to Sales Tax?
By Roy E. Crawford on Jun 10, 2014
Posted In Massachusetts, Sales Tax
As noted in an earlier blog post, “[a] trend is developing in response to aggressive Department of Revenue/Treasury policy-making regarding cloud computing.” This trend has not been friendly to aggressive Departments, and it appears that the Massachusetts Department of Revenue (Massachusetts Department) may be subtly moving away from its own aggressive position regarding one type...
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