California’s 20-Year Tax Collection Clock Has a Constitution Problem
A 1932 amendment to the California Constitution presumes every tax paid after 30 years. No court has said it covers income tax.
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Insights
Short tax notes, articles, and external commentary on federal and California tax planning, controversy, and transactional tax issues.
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Longer, more polished pieces hosted on Medium or external publications.
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Shorter posts hosted directly on galek.tax.
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Tax Notes, Tax Notes State, Canadian Accountant, Medium, and other placements.
Let's Be Reasonable: Sourcing California's Restricted Stock Unit Income
Discussion on California's grant-to-vest formula for sourcing RSU income as one reasonable method, with reasonableness, not the formula, as the regulatory standard.
Severable Water Rights As IRC § 170 Charitable Deduction Property
Principal author of an article discussing the need for guidance on charitable deductions for donation of an entire interest in water rights severable from real property under state law.
A Taxonomy Of Tax Professionals
A discussion of the various tax professionals in the U.S. and Canada who assist taxpayers in both countries.
Articles are for general informational purposes only and do not constitute legal, tax, or other professional advice.