Insights on California Tax Issues with Michael Cataldo (Part 2)

SALTovation: Making Sense of State and Local Tax

Jul 20 2022 • 24 mins

In the second episode of a two-part series, Meredith Smith and Stacey Roberts, from TaxOps’ SALTovation Team, continue their conversation with Michael Cataldo, of Cataldo Tax Law in California. Michael continues to share his insight on the publications released by the Franchise Tax Board, that discuss sales of services and market-based sourcing in California. He also talks about some of his favorite cases outside the state.

Topics discussed in this episode:

  • Recent ruling regarding California’s sales of services and market-based sourcing
  • California’s most recent ruling on sales of service

What You Will Learn:

  • [00:28] California’s policy on alternative proportment
  • [01:51] Sales of services in California
  • [09:51] Michael’s favorite cases outside of California
  • [15:05] Retroactive tax laws
  • [19:05] What creates nexus
  • [21:06] Regulations on market-based sourcing


  • “It’s very hard to articulate exactly what was going on, what they’re doing. You have to do a lot of reading between the lines, see what they’re trying to do.” - Michael Cataldo [02:21]
  • “The things I get interested in is where’s this going from here? And it takes a long time for things to develop in the state and local tax world to where this is going.” - Michael Cataldo [11:29]
  • “Technology is moving so fast and what’s not going online. There’s going to be some challenges for them to figure out how to comply.” - Michael Cataldo [14:27]
  • “But the constitution applies to all the states, so these constitutional arguments apply to all of them.” - Michael Cataldo [20:11]

Relevant Links:

Cataldo Tax Law:

Michael Cataldo on LinkedIn: