Marcy Jo Mandel

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Marcy Jo Mandel focuses her practice on state and local tax (SALT) controversies, in addition to advising clients of federal tax controversies, corporate mergers and acquisitions, and provides state tax strategies for clients on a full range of state tax issues. Read Marcy Jo Mandel's full bio.

OTA Finds CDTFA’s Audit Methodology Arbitrary

By , , and on Jul 24, 2023
Posted In Audits, California, Sales Tax

In Appeal of Colambaarchchi (OTA Case No. 21017152; 2023-OTA-302), a California-based retailer was audited by the California Department of Tax and Fee Administration (CDTFA) for years 2016 through 2019. Upon audit, CDTFA determined that taxable sales went unreported. In calculating the extent of the underreporting, CDTFA used various indirect methods for different periods in the...

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Is California Picking the Pockets of Other States?

By , , and on Oct 21, 2022
Posted In California, Local Tax, Nationwide Importance, Sales Tax, Transaction Taxes

In Matter of Body Wise International LLC (OTA Case No. 19125567; 2022 – OTA – 340P), a California-based retailer collected amounts designated as “tax” related to jurisdictions where it was not registered to collect tax. The California Office of Tax Appeals (OTA) held that the retailer must remit those amounts to California, even though the...

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CDTFA Proposes Significant Revisions to Chapters 4 and 13 of the Sales Tax Audit Manual

By , , and on Feb 10, 2022
Posted In Audits, California, Local Tax, Nationwide Importance, Sales Tax

On February 2, 2022, the California Department of Tax and Fee Administration (CDTFA) held an interested parties meeting (IPM) to discuss proposed amendments to sales tax audit manual (AM) Chapter 13, “Statistical Sampling,” and Chapter 4, “General Audit.” Prior to the IPM, the CDTFA released a lengthy discussion paper outlining the extensive proposed changes to...

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Governor Newsom Announces New Relief for Remitting California Sales Tax

By , , and on Dec 1, 2020
Posted In California, Interest and Penalties, Nationwide Importance, Sales Tax

On Monday, November 30, 2020, Governor Gavin Newsom announced that California will provide temporary tax relief for eligible businesses impacted by restrictions imposed to control the COVID-19 pandemic. The announcement indicates that the Governor will direct the California Department of Tax and Fee Administration (CDTFA) to: Provide an automatic three-month extension for taxpayers filing less...

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Taxes, Like Temperatures, Going Up: California COVID-19 Budget “Revenue Solutions”

By and on May 15, 2020
Posted In California, Franchise Tax, Income Tax, Local Tax, Sales Tax

Yesterday Governor Gavin Newsom turned to a familiar gambit from California’s playbook to help tackle the budgetary hole wrought by COVID-19. In January, the Governor proposed his budget for the 2020-2021 fiscal year, which projected a $5.6 billion surplus. Indeed, revenues through March are reported as having run $1.35 billion above projections. But, as the...

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Governor Newsom Signs Executive Order Providing Last Minute Property Tax Relief

By , , and on May 7, 2020
Posted In California, Property Tax

On Tuesday we authored a blog post commending San Francisco County Assessor Carmen Chu for moving the deadline for businesses to file their Business Property Statements (Form 571-L) to June 1 of this year. We noted that California statutory authority provides that if the property tax filing deadline falls on a date when the county...

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Last Minute Relief for Filers of Business Property Statements

By , , and on May 5, 2020
Posted In California, Local Tax, Procedure, Unitary Business

Once again, San Francisco has shown leadership in addressing property tax relief during the COVID-19 pandemic. On Monday, May 4, 2020, the San Francisco County Assessor announced that she was moving the deadline for businesses to file their Business Property Statements (Form 571-L) to June 1 of this year, due to physical office closure of...

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