Press Release 07.28.25
Annie Huang focuses on state and local tax matters, including corporate franchise/income, personal income, sales and use, and gross receipts and other local taxes.
Her practice consists of state and local tax controversies at both administrative and judicial levels, tax planning and transactional work. Annie regularly practices before the California Franchise Tax Board, the California State Board of Equalization and the California Office of Tax Appeals. She also represents clients before administrative tribunals and state tax courts in other jurisdictions throughout the country. Prior to joining the firm, she was a tax counsel to one of the members of the California Board of Equalization.
Representative Experience
- Served as lead counsel in a major California personal income tax appeal before the SBE, involving contentious residency and sourcing-of-income issues. Successfully abated a multimillion-dollar assessment for clients Michael J. and Mary E. Bills.
- Represented Apple in a case involving taxation of foreign dividends and disallowance of interest expense deductions in a water’s-edge setting, setting precedent as California Court of Appeal fully allowed Apple’s interest expense deductions.
- Argued the lead case in New Jersey Tax Court involving interest add-back provisions, prevailing as the court concluded that taxpayer Beneficial New Jersey’s interest expense deductions should be allowed under the unreasonable exception.
View More
- Served as lead counsel for high-net-worth individuals in a California residency case that was resolved at the protest level, resulting in a 90 percent reduction of $37 million in proposed personal income tax assessments.
- Served as lead counsel in a New York high-net-worth residency case that was resolved at audit level, resulting in a 95 percent reduction of a potential assessment in excess of $1 million.
- Represented General Electric Co. in lawsuit against California’s Franchise Tax Board challenging the validity of its controversial amnesty penalty.
- Represented McGraw-Hill Cos. in refund action at FTB involving whether a book publisher’s use of the mark-to-market method of accounting for its customer paper, which was allowed for federal income tax purposes, should be allowed for California purposes.
- Successfully defended Beneficial California in an SBE appeal involving expense attribution issues, thwarting an FTB attempt to disallow a portion of the taxpayer’s interest expense deduction.
- Represented Save Mart Supermarkets in an SBE appeal involving whether it was a qualified taxpayer for purposes of the Manufacturers’ Investment Credit, prevailing in the first MIC case decided by the SBE.
- Successfully argued at SBE that client Esprit de Corp.’s interest expense, incurred to fund a leveraged buyout, was wholly allocable to California, the state of commercial domicile.
Professional Highlights
Honors & Awards
- Chambers USA, Tax: State & Local – California (2007 – 2008)
- The Legal 500 U.S., Tax Controversy (2010 – 2012, 2014 – 2015)
- Tax Disputes/Controversy Leaders’ Guide, International Tax Review (2011)
View More
- Associations
- Past chair, Taxation Section, Barristers Club, Bar Association of San Francisco (2005 – 2006)
- Past chair, State and Local Tax Committee of the California State Bar Taxation Section (2007 – 2008)
- Publications
- “Hidden within the Transparency and Fairness Act of 2017 Was the Little Noticed Exemption from OAL Review of the CDTFA’s Proposed Regulations,” SeeSALT Blog Post, with Richard E. Nielsen, April 14, 2021.
- “California Court of Appeal Concludes That a Trust with a Non-California Trustee May Be Subject to Tax on All of Its Gain from the Sale of Stock,” SeeSALT Blog Post, with Jeffrey M. Vesely, August 6, 2020.
- “Hyatt to Make Second Trip to the United States Supreme Court in Continuing Battle with the Franchise Tax Board,” with Michael J. Cataldo, Paul T. Casas, July 13, 2015.
- “California Tax Board Provides Guidance on the Broadened Definition of ‘Retailer Engaged in Business in This State,’” with Jeffrey M. Vesely, Paul T. Casas, June 5, 2012
- “Tax Provisions of the 2010 – 2011 California Budget,” with Jeffrey M. Vesely, Michael J. Cataldo, October 19, 2010.
- “New Jersey Tax Court Decides in Favor of Taxpayer in First Interest Addback Case,” with Jeffrey M. Vesely, September 7, 2010.
- Speaking Engagements
- “Best Practices in Sourcing for Both Sales and Income Taxes,” COST State and Local Tax Workshop for the Tech Industry, August 2021, Webinar.
- “California Market-Based Sourcing Issues,” COST Central West Regional State Tax Webinar, March 2021, Webinar.
- “Top 5 Income Tax Trends,” TEI Chicago Chapter SALT Program, December 2020, Webinar.
- “Market Sourcing through Alternative Apportionment or Creative Characterizations of Activity,” COST 51st Annual Meeting, October 2020, Webinar.
- “Market-Based Sourcing: What’s Happening at Audit and Appeal?,” TEI Silicon Valley Chapter’s SALT Day & IPT Joint Meeting, December 2019, Santa Clara, CA.
- “California’s OTA: Friend or Foe?,” TEI Silicon Valley Chapter’s SALT Day & IPT Joint Meeting, December 2019, Santa Clara, CA.
- “Market-Based Sourcing,” COST 50th Annual Meeting, October 2019, Washington, DC.
- “U.S. Constitutional Limitations on State Taxation,” COST Forum on U.S. State and Local Taxes for European Companies, June 2019, London, UK.
- “The State of State and Local Taxes,” TEI’s New York State and Local Chapter Meeting, March 2019, New York, NY.
- “Special Report – Recent Developments in California Taxes: Issues and Opportunities,” COST Pacific Southwest Regional State Tax Seminar, November 2018, Glendale, CA.
- “National Judicial Update and Discussion of State Tax Cases – Including Wayfair –,” COST Pacific Southwest Regional State Tax Seminar, November 2018, Glendale, CA.
- “Best Practices for Dispute Resolution at the Formal Appeal and Litigation Levels Using California as a Model,” COST Pacific Southwest Regional State Tax Seminar, November 2018, Glendale, CA.
- “California and Arizona Updates,” COST 49th Annual Meeting, October 2018, Phoenix, AZ.
- “California and Arizona Updates,” COST 48th Annual Meeting, October 2017, Orlando, FL.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch,” COST California & Pacific Northwest Regional State Tax Seminar, March 2017, San Francisco, CA.
- “Recent Developments in Alternative Apportionment, Market-Based Sourcing and Related Issues,” COST California & Pacific Northwest Regional State Tax Seminar, March 2017, San Francisco, CA.
- “Did You Catch the Fight? – An Update on Recent SALT Litigation,” California Tax Policy Conference, October 2016, San Diego, CA.
- “California and Arizona Updates,” COST 2016 47th Annual Meeting/Fall Audit Session, October 2016, Las Vegas, NV.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch,” COST Pacific Southwest Regional State Tax Seminar, June 2016, Los Angeles, CA.
- “Alternative Apportionment and Forced Combination,” COST Pacific Southwest Regional State Tax Seminar, June 2016, Los Angeles, CA.
- Current Developments in State and Local Taxes – Speech before the North Bay Tax Directors, June 2016.
- “California and Arizona Update,” COST 2016 Spring Audit Session/Income Tax Conference, April 2016, Asheville, NC.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch,” COST 2016 Pacific Southwest Regional State Tax Seminar, February 2016, Phoenix, AZ.
- “Alternative Apportionment Developments,” COST 2016 Pacific Southwest Regional State Tax Seminar, February 2016, Phoenix, AZ.
- “I Swear It Wasn’t Willful Neglect! Making the Case for Penalty Abatement in California – 2015,” Annual Meeting of the California Tax Bar and California Tax Policy Conference, November 2015.
- “California and Arizona Updates,” COST 2015 46th Annual Meeting/Fall Audit Session, October 2015, La Jolla, CA.
- “The Future of State Taxation,” TEI San Diego Chapter State & Local Tax Seminar, September 2015, San Diego, CA.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch,” TEI San Diego Chapter State & Local Tax Seminar, September 2015, San Diego, CA.
- “The Future of State Taxation,” TEI Orange County Chapter State & Local Tax Day, May 2015.
- “Key California Developments,” TEI Orange County Chapter State & Local Tax Day, May 2015.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch,” TEI Orange County Chapter State & Local Tax Day, May 2015.
- “California and Arizona Update,” COST 2015 Spring Audit Session/Income Tax Conference, April 2015, Memphis, TN.
- “Alternative Apportionment Developments,” COST Pacific Southwest Regional State Tax Seminar, February 2015, Phoenix, AZ.
- “Discussion of State Tax Cases, Issues and Policy Matters to Watch in 2015,” COST Pacific Southwest Regional State Tax Seminar, February 2015, Phoenix, AZ.
Education
-
J.D., University of California, Los Angeles, School of Law, 1996
B.A., University of California, Berkeley, 1993
Admissions
-
California
Languages
-
Chinese (Mandarin)