California Tax Litigation: Nexus Battles, Retroactive Laws, and Apportionment Disputes episode artwork

EPISODE · Mar 25, 2026 · 32 MIN

California Tax Litigation: Nexus Battles, Retroactive Laws, and Apportionment Disputes

from SALTovation: Navigating the Complexities of State and Local Tax by Aprio

In part two of Aprio’s conversation with Michael Cataldo from Cataldo Tax law firm, we explore the distinction between business and non-business income and the complexities of the throw-out rule in California’s evolving tax landscape. Michael also highlights current cases to watch and explains why early issue identification is critical for taxpayers. The discussion will also cover how major transactions can trigger sourcing disputes and why practitioners should stay proactive with return reviews and apportionment strategies to help reduce audit risk. Key Takeaways:Business vs. non-business income: Classification determines whether income is apportioned or allocated.Throw-out rule: Ongoing disputes over the treatment of “nowhere sales.”Large transactions: Business sales often trigger complex sourcing issues.Early issue identification: Proactive return review helps reduce audit riskConnectVisit us on our website: https://www.aprio.com/business-tax/state-local-tax-salt-consulting/ Subscribe on your favorite podcast app here.Follow us on LinkedIn and YouTube.Disclaimer: The views, thoughts, and opinions expressed on the SALTovation podcast, including that of all participants, are the speaker’s own and do not represent the views, thoughts, and opinions of Aprio or any of its affiliates. The material and information presented on the podcast is for general information purposes only. The “Aprio” name and all forms and abbreviations are the property of its owner and its use does not imply endorsement of or opposition to any specific product or service.Mentioned in this episode:Schedule a Call with the Aprio Team Now!Introductory Call

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California Tax Litigation: Nexus Battles, Retroactive Laws, and Apportionment Disputes

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This episode was published on March 25, 2026.

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In part two of Aprio’s conversation with Michael Cataldo from Cataldo Tax law firm, we explore the distinction between business and non-business income and the complexities of the throw-out rule in California’s evolving tax landscape. Michael also...

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