<p style="margin: 0in;">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 Shail also discusses his--and many others--surprise that this decision has initially been marked non-precedential and what could be done to change that.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. </p>

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 Shail also discusses his--and many others--surprise that this decision has initially been marked non-precedential and what could be done to change that.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.

<p>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).&nbsp;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deduction.&nbsp;Shail also discusses his--and many others--surprise that this decision has initially been marked non-precedential and what could be done to change that.&nbsp; Finally, Nikki and Shail discuss summer cocktails.&nbsp; And, of course, Frankie has a few things to say during the conversation as well.&nbsp;</p>

California OTA Catch-up

GeTtin’ SALTy is a podcast hosted by Greenberg Traurig, focusing on state and local tax policy, legislative, regulatory and litigation updates.  The GT SALT Practice assists companies in need of state and local tax counsel whether in a single location or multiple locations throughout the United States. With the largest footprint of any law firm in the United States, the SALT Practice has attorneys in 16 of the firm’s domestic offices, including California, Colorado, Delaware, Illinois, Florida, New York, Oregon, and Texas. The firm’s breadth of experience across the full SALT spectrum allows GT to offer a wide range of services, including counseling and controversy. The team also regularly partners with the firm’s nationally recognized Government Law and Policy Practice to help shape the tax law which affects our clients most.

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GeTtin’ SALTy is a podcast hosted by Greenberg Traurig, focusing on state and local tax policy, legislative, regulatory and litigation updates. The GT SALT Practice assists companies in need of state and local tax counsel whether in a single location or multiple locations throughout the United States. With the largest footprint of any law firm in the United States, the SALT Practice has attorneys in 16 of the firm’s domestic offices, including California, Colorado, Delaware, Illinois, Florida, New York, Oregon, and Texas. The firm’s breadth of experience across the full SALT spectrum allows GT to offer a wide range of services, including counseling and controversy. The team also regularly partners with the firm’s nationally recognized Government Law and Policy Practice to help shape the tax law which affects our clients most.

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California OTA Catch-up

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