Taxation Section

News from the Section

Greetings from the 2015-2016 Chair

Robert HorwitzHere you will find news of upcoming activities of the Taxation Section, which is California's only statewide tax bar association. The Section's current membership is approximately 3,000, and we invite you to join. Membership in the Taxation Section provides an unparalleled opportunity to meet and interact with other tax practitioners and government officials throughout California, influence tax policy and legislation, and to serve on one of the Section's many Standing Committees. The Taxation Section sponsors timely and cutting edge educational programs by leading practitioners in the State.

This year, the Taxation Section will be undertaking three new initiatives. First, we will be formally commenting on proposed IRS regulations. Second, we will be formally commenting on proposed tax legislation pending before the California Legislature. Third, Taxation Section members will be participating in State Bar Town Hall meetings to provide timely information to members of disadvantaged communities.

Robert S. Horwitz
Chair, Taxation Section
Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA

2016 Sacramento Delegation

February 4-5, 2016
Sacramento, California

In 2013, the Taxation Section revived its annual delegation to Sacramento, where tax practitioners present papers on topics of concern to high-ranking officials of the Board of Equalization, Franchise Tax Board and Legislative staff. The meetings take place in the Capital Building. The proposals and comments contained in the papers are the individual views of the authors who prepared them, and do not represent the position of the State Bar of California or the Taxation Section of the State Bar.

The 2016 Sacramento Delegation is set for February 4-5, 2016. The delegation begins at a rehearsal dinner on the evening of February 4, followed on February 5 by presentation of papers at the Capitol Building in Sacramento. Several papers in the past resulted in legislation proposed to the State Legislature and changes in agency policy. Jenna Lewis will lead the 2016 Delegation. If you are interested in participating in the Sacramento Delegation, please contact:

Jenna Lewis
Franchise Tax Board
Legal Division MS A-260
PO Box 1720
Rancho Cordova, CA 9574

2016 Estate & Gift Tax Conference

February 25-26, 2016
University of San Francisco School of Law
San Francisco

This year's Estate & Gift Tax Conference will be held over two days in a new venue, the University of San Francisco School of Law. Prominent speakers from private practice and government will present programs on the latest developments in estate and gift tax. It is a program that all estate and gift tax practitioners and trust and estate attorneys need to attend. More information will be available online at the Taxation Section webpage of the State Bar website.

2016 D.C. Delegation

May 1-3, 2016
Washington, D.C.

For over 20 years, the Taxation Section has sent an annual delegation of tax attorneys to Washington, D.C., to present papers on issues of concern to California tax practitioners. The Delegation meets with key government officials at IRS National Office, Treasury Department, Joint Committee on Taxation, House Ways and Means Committee, Senate Finance Committee, United States Tax Court and Department of Justice Tax Division.

Kaelyn Romey will lead the 2016 Delegation. If you are interested in writing and presenting a paper as part of the 2016 D.C. Delegation, please contact:

Kaelyn Romey
Office of Chief Counsel
100 1st St 18th Fl.
San Francisco, CA 94105


International Taxation - Part II: Corporate

Wednesday, November 18, 2015, 12 noon - 1 p.m. (Pacific)

This program offers 1 hour participatory MCLE credit and 1 hour legal specialization credit in Taxation Law. You must register in advance in order to participate.

This webinar will discuss International Taxation of Businesses:

  • Theories for taxing multinational enterprises:
    • Capital export neutrality
    • Capital import neutrality
    • What the US and other countries do
    • Concern over stateless income resulting in "double nontaxation".
  • Corporate forms of base erosion and profit shifting (BEPS)
    • Objective- minimize taxation of offshore earnings and lower effective tax rate Rationale- U.S. taxes worldwide income. Shift in domicile isolates U.S. taxation to U.S. income.
  • Methods
    • Inversions- corporations re-domicile to low tax jurisdiction
      • Big Pharma mergers
      • Burger King merger
    • Transfer of intellectual property to offshore low tax jurisdiction
      • Technology companies
      • Pharmaceuticals
    • Supply chain management
    • Transfer pricing
    • Manufacturing and supply chain based shift in costs
  • Response of Executive Branch and Congress
    • Executive Branch- Treasury suggests Regulation option
    • Congress- Legislative proposals
    • Proposed changes to US Income Tax Model Treaty

Speaker: William Norman

Moderator: Sanford Millar

Property Tax Change in Ownership 101

Tuesday, December 8, 2015, 1 p.m. - 2:30 p.m. (Pacific)

This program offers 1.5 hour participatory MCLE credit and 1.5 hour legal specialization credit in Taxation Law. You must register in advance in order to participate.

This program is invaluable for all California real estate, corporate, and tax attorneys who advise clients who are regularly engaged in buying, selling, or leasing property. The webinar will provide participants with a toolkit to help analyze and handle various factual scenarios. The speaker will focus on the basic change in ownership rules, defining when a change in ownership occurs, and when a change in ownership can legally and safely be avoided.

Speaker: Bradley Marsh

469 Passive Activity Rules related to Real Estate Professionals

Friday, January 8, 2015, 12 noon - 1 p.m.(Pacific)

This program offers 1 hour participatory MCLE credit and 1 hour legal specialization credit in Taxation Law. You must register in advance in order to participate.

This webinar will review the 469 Passive Activity rules, and discuss strategies for real estate professionals.


  • Laura Buckley, Partner, Higgs, Fletcher & Mack, LLP
  • Brad A Gastineau, Partner, Gatto, Pope & Walwick, LLP

Articles Sought

California Journal of Tax Litigation

Tax Procedure and Litigation Committee

The California Journal of Tax Litigation is published quarterly by the Tax Procedure and Litigation Committee. Articles are being solicited for upcoming editions of the journal. The journal contains articles on current issues in tax litigation and procedure. Send your submissions to: Aubrey Hone, Hone & Maxwell, 870 Market St #586, San Francisco, CA 94102, 415-765-7516.

California Tax Lawyer

California Tax Lawyer, the Taxation Section's official publication, is sent free to members of the Section. The journal is designed to keep tax lawyers and other tax professionals apprised of the latest developments in the field, as well as up-to-date on the activities of the Section. To receive a subscription, you need only Join the Section.

Anyone can submit an article to the Editors for consideration for publication in California Tax Lawyer. Submissions are typically due February 15, May 15, August 15, and November 15. For more information, please read these guidelines on the Taxation Section website.

Social Media

FacebookTwitterThe Taxation Section maintains a Facebook account,, and a Twitter account,  We will be posting regularly, so like us on Facebook and follow us on Twitter.

Meet Your Executive Committee

The Taxation Section is managed by its Executive Committee, which meets quarterly and is comprised of tax lawyers working in private law firms, accounting firms, government, and corporations throughout California. See contact information for the current Executive Committee members, or see the appointments process for information on becoming a member of the Executive Committee in the future. We encourage you to become involved.

Online CLE for Participatory Credit -- Available Anytime!

Past programs are available over the internet for participatory MCLE credit. For more information, see online CLE and select Taxation Section. Be sure to check out CLEtoGo if you're interested in downloadable podcasts.

Get Involved

The Taxation Section relies on the energy, effort, and dedication of the members of the California tax practitioner community.  We encourage all members of the Taxation Section to get involved in the section - your section.  Here are some things you can do right now:

  • Join a Standing Committee
  • Attend a meeting held by one of the many Standing Committees
  • Propose a topic for the Washington, D.C. Delegation
  • Propose a topic for the Sacramento Delegation
  • Propose a program for the State Bar Annual Meeting
  • Propose a program for the Annual Meeting of the California Tax Bar and California Tax Policy Conference
  • Write an article for California Tax Lawyer

Save Money with CEB

CEB LogoContinuing Education of the Bar, California (CEB) is extending a special offer to our section. As a member of the Taxation Section, you're eligible for a rebate on your section dues that can be applied to the cost of a CEB Gold CLE Passport or a CLE program ticket. Information about the section dues rebate program can be found on the CEB Web site.

Contact Us

Taxation Section
The State Bar of California
180 Howard Street
San Francisco, CA 94105-1369
FAX 415-538-2368

The Taxation Section is a State Bar of California-approved MCLE provider.

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