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Calif. Tax Board nonresident asset ruling raises new issues

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Earlier this month, the California Franchise Tax Board released Legal Ruling 2022-02, regarding the sourcing of Internal Revenue Code Section 751(a) gain from the disposition of a nonresident individual’s partnership interest when the IRC Section 751 property is located in California.

In this article for Law360, Eversheds Sutherland Senior Counsel Eric Coffill discusses the nonresident asset ruling and its potential impact, especially where Section 751 property is involved.

Read the full article here.

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