Natlawreview iconNatlawreviewOct 16, 2026 ~1 min source read

California OTA Rejects FTB's IRC Section 751 Partnership Sourcing Theory

In a significant development for nonresident investors and private equity structures, the California Office of Tax Appeals (OTA) held that gain attributable to IRC section 751(a) “hot assets,” such as unrealized receivables and inventory items, remain part of the sale of a partnership interest. As the sale of an intang

California OTA Rejects FTB's IRC Section 751 Partnership Sourcing Theory

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