Latest / North Star Tax and Legal Briefing
Selling an S Corporation Division: California’s Unitary Test After Western Distributing
An S corporation sells one division to an out-of-state buyer. Can California tax the gain? A June 2026 Office of Tax Appeals opinion, Western Distributing, shows how the unitary business test decides it, why calling the gain nonbusiness income backfires, and what division-level books an owner needs years before a sale. Full analysis: https://ca-legal.net/california-unitary-business-s-corporation-division-sale-western-distributing/
The skinny
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