Business owners, officers, managers, investors, and financial personnel often assume that a corporation or limited liability company protects them from business tax debts. In many situations, limited liability is an important protection. But California sales and use tax is different.

The California Office of Tax Appeals’ June 2026 business tax opinions include V. Moody, 2026-OTA-300, a nonprecedential opinion involving responsible person liability under Revenue and Taxation Code section 6829. OTA’s listing identifies the issue as “Responsible person liability (R&TC 6829).”

For anyone connected to a business with unpaid California sales tax, the issue is serious. CDTFA may attempt to collect the entity’s unpaid sales and use tax from an individual if the statutory requirements are met.

California taxpayers often focus on whether they overpaid tax. That is understandable, but in a refund dispute, being right on the numbers is not always enough. If the refund claim is filed too late, the California Franchise Tax Board may deny the claim without ever reaching the merits.

Recent California Office of Tax Appeals opinions reinforce that point. OTA’s June 2026 franchise and income tax opinions include J. Lord and D. Lord, 2026-OTA-304, a nonprecedential decision involving the statute of limitations on a claim for refund under Revenue and Taxation Code section 19306. OTA’s June 2026 list also includes many other refund statute cases, showing that missed refund deadlines remain a recurring problem in California tax controversy.

The California Office of Tax Appeals has posted its current opinion-cycle notice, reminding taxpayers and practitioners that comments on whether opinions posted on June 1 should or should not be designated as precedential are due by June 29. OTA also states that new opinions will be posted on July 6.

For many taxpayers, this may sound like a narrow administrative update. It is not. OTA opinions can shape how California tax disputes are decided, especially when an opinion becomes precedential. Businesses, individuals, tax professionals, and taxpayers with pending California appeals should understand why these opinion cycles matter.

The IRS’s 2025 Data Book shows a tax agency under pressure. The IRS still processed hundreds of millions of returns and collected trillions of dollars, but audit closures and recommended additional tax declined from the prior year. At the same time, staffing reductions and operational strain may affect how quickly the IRS handles audits, notices, refunds, identity-theft cases, correspondence, and appeals.

For taxpayers, the practical lesson is not that IRS enforcement has disappeared. It has not. The lesson is more nuanced: IRS enforcement may become less predictable, more automated in some areas, more selective in others, and slower when human review is required.

That combination can be difficult for taxpayers. A lower audit rate does not necessarily mean a lower risk of IRS contact. It may mean fewer traditional audits, more document-matching notices, longer response times, delayed resolutions, and greater importance placed on records, transcripts, and procedural deadlines.

The IRS has announced a new time-limited settlement opportunity for eligible partnerships involved in syndicated conservation easement and historic preservation easement disputes. For investors still involved in these cases, the offer deserves careful review.

The IRS has partially acquiesced in the Tax Court’s decision in Abdo v. Commissioner, but only in a narrow way. In an Action on Decision published in Internal Revenue Bulletin 2026-23, the IRS agreed only with the Tax Court’s limited holding that the COVID-19 federal disaster declarations created a mandatory 60-day postponement period from January 20, 2020, to March 20, 2020.

The IRS did not agree with the Tax Court’s broader reasoning. It also did not agree with the court’s invalidation of portions of the Treasury regulations or with any interpretation that would extend the COVID-19 postponement period beyond that 60-day window.

For taxpayers, this is more than a technical procedural development. The issue affects Tax Court filing deadlines, refund claims, penalty abatement requests, interest disputes, disaster postponement rules, and the IRS’s approach to taxpayer arguments based on Internal Revenue Code section 7508A.

Out-of-state businesses selling into California often assume that limited in-state activity will not expose them to California income or franchise tax. A recent California Office of Tax Appeals matter shows why that assumption can be risky.

The California Office of Tax Appeals lists Ken’s Foods, Inc., 2026-OTA-249P, as a June 2026 pending precedential opinion. The issue is whether the taxpayer’s California activities exceeded the protection of Public Law 86-272.

For businesses that sell tangible personal property into California, this is an important development. Public Law 86-272 can provide a narrow federal protection against state net income taxes when a company’s in-state activities are limited to protected solicitation. But the protection is not unlimited, and California tax authorities have continued to examine whether a company’s actual in-state activities go beyond solicitation.

Taxpayers often believe that if enough years pass, the IRS can no longer assess or collect old taxes. Sometimes that is true. Federal tax procedure includes statutes of limitations that restrict how long the IRS has to assess tax, how long the IRS has to collect assessed tax, and how long a taxpayer has to claim a refund.

But the rules change dramatically when a taxpayer never filed a return. In that situation, the normal three-year assessment period may never begin. The IRS may prepare a substitute for return, assess tax, and begin collection. Even after the IRS prepares a substitute return, the taxpayer may still need to file a valid original return to start the assessment statute and correct the government-prepared assessment.

For taxpayers with unfiled returns, substitute-for-return assessments, old balances, or refund claims, the statute of limitations analysis can be more complicated than it appears.

California’s Franchise Tax Board recently highlighted an important conformity update for tax-exempt organizations. In its June 2026 Tax News, FTB explained that Senate Bill 711 updated California’s conformity to Internal Revenue Code section 512 as of January 1, 2025, subject to California-specific modifications.

For California nonprofits and other exempt organizations, this matters because California is now aligning more closely with the federal rules requiring separate reporting of unrelated business taxable income, commonly referred to as UBTI, for each unrelated trade or business under IRC section 512(a)(6).

This is not merely a form change. It may require exempt organizations to revisit how they identify unrelated business activities, track revenue and expenses, allocate shared costs, preserve net operating loss information, and prepare for future California reporting requirements.

The Treasury Department and IRS have announced that they intend to issue proposed regulations addressing the excise tax on excess compensation and excess parachute payments paid by applicable tax-exempt organizations. The announcement, issued in Notice 2026-36, follows statutory changes that expanded the reach of Internal Revenue Code section 4960.

This is an important development for nonprofits, hospitals, universities, private foundations, tax-exempt affiliates, supporting organizations, and related entities that pay significant compensation to executives, physicians, investment professionals, athletic personnel, administrators, or other highly compensated employees.

The issue is no longer limited only to the five highest-compensated employees of a tax-exempt organization. Under the expanded rules, the tax may apply more broadly to any employee with compensation exceeding $1 million in a tax year or to an employee who receives an excess parachute payment.

That change can create new tax exposure, governance concerns, reporting obligations, and compensation-planning issues for organizations that may not have previously viewed themselves as subject to IRC section 4960 risk.

The Tax Court’s recent decision in Paschall v. Commissioner, T.C. Memo. 2026-46, is an important development for taxpayers who receive cryptocurrency staking rewards. The case addressed a question that has been heavily debated in the digital-asset tax community: are staking rewards taxable when received, or only later when the taxpayer sells or exchanges the tokens?

For California tax purposes, moving out of the state is important, but it is not always enough. The Franchise Tax Board may examine whether the taxpayer truly changed domicile, whether the taxpayer remained a California resident, whether the taxpayer’s absence from California was temporary or transitory, and whether any income remains California-source even after the move.

Lawsuit settlements often end with a signed agreement, a release, and a payment. For tax purposes, however, the matter may not be over when the settlement funds are disbursed. Months later, the plaintiff, counsel, or both may receive one or more IRS Forms 1099 reporting some or all of the settlement proceeds. That reporting can be confusing, and in some cases it can create a mismatch between how the parties viewed the settlement and how the payment is later reported to the IRS.