A widely respected thought leader on state and local tax issues, Eric Coffill brings 35 years of experience counseling clients on multistate tax controversy and litigation matters.

Eric counsels clients at the administrative, trial and appellate levels, particularly before the California Franchise Tax Board (FTB) and State Board of Equalization (SBE).

He advises manufacturers, government contractors, technology service providers and other industry-leading companies on all aspects of state and local taxes, including transactional, income, nexus and apportionment issues.

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A former staff counsel to the California FTB and public defender for the Office of the California State Public Defender, Eric has extensive experience advising on California tax matters, having successfully litigated cases before the Supreme Court of California, the California FTB and the California SBE. Eric litigated the landmark case defining corporate business income. [Hoechst Celanese Corporation v. Franchise Tax Board (2001) 25 Cal.4th 508]

Eric is the author of more than 80 articles on a variety of state tax issues. His wealth of knowledge and experience in state tax disputes allows him to effectively advocate for his clients and has made him a sought-after speaker for numerous organizations, such as Tax Executives Institute (TEI). Eric currently teaches income and franchise taxation at the University of California, a position he has held since 1991. He also served as a state and local tax adjunct professor at McGeorge School of Law for nearly 10 years.

Prior to joining Eversheds Sutherland (US), Eric was managing partner of the Sacramento office of Morrison & Foerster LLP.

Professional Highlights

Named as “Band 1” Recommended for State & Local Tax in Chambers USA: America's Leading Lawyers for Business (2007- 2018).


2017 “Lawyer of the Year - Tax,” Best Lawyers of America.


Life Fellow, American Bar Association

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  • Taught corporate state income tax at the UC Davis School of Law, Summer Tax Institute, sponsored by the Center for State and Local Taxation
  • Honors and Awards
    • Listed in San Francisco Magazine as a Northern California “Super Lawyer”(2004-2017).
    • Named in Best Lawyers of America (2010-2019) (Litigation and Controversy – Tax; Tax Law).
    • Sacramento Magazine's “Top Lawyers List,” Tax, 2016.
    • Named “Recommended” in Legal 500 for State Tax, (2009, 2013-2015.)
    • Named Leading Tax Controversy Advisor, International Tax Review, 2012.
    • Benjamin F. Miller Award, State Bar of California, Taxation Section, 2010.
    • Award for Exceptional Contributions for Delivery of Legal Services to Prisoners, State Bar of California, Legal Services Section, 1982.
    • Sustained Superior Accomplishment Award for Exceptional Job Performance, California Franchise Tax Board, 1988.
  • Associations & Professional Acitivites
    • Life Fellow, American Bar Association
    • Member, Editorial Board, Journal of Multistate Taxation and Incentives
    • Member, Tax Section, American Bar Association
    • Member, Tax Section, State Bar of California.
    • Member, State Tax Notes Advisory Board (since 1996).
    • Member, Editorial Board (Taxation), Journal of Multistate Taxation and Incentives (since 2015).
    • IPT Co-Chair of the ABA/IPT Advance Income Tax Seminar Committee (since 2015).
  • Previous Associations
    • Member, Board of Directors, California Taxpayers Association (2012 – 2015).
    • Member, Tax Committee, California Chamber of Commerce (1993-2004).
    • Member, Editorial Advisory Board, The State and Local Tax Lawyer, published by Section of Taxation, American Bar Association, Region 1, Regional Editor (1998-2000).
    • Member, Sacramento Area Commerce and Trade Organization (SACTO), European Committee (1997-2000).
    • Member, Juvenile Justice Committee, State Bar of California (1982-1983).
    • Member, Standing Committee on Legal Services to Prisoners, Legal Services Committee, State Bar of California (1980-1983).
  • Publications
    • An Interview With California Tax Agency Director Nicolas Maduros, State Tax Notes (July 30, 2018)
    • “Some Observations on Gross Receipts Taxes,” Journal of Multistate Taxation and Incentives, Vol. 28, No. 4 (July 2018)
    • An Interview With California BOE Chair Diane Harkey, State Tax Notes (January 15, 2018)
    • “California's Altered Tax Landscape. The Decline of the Board of Equalization and the Rise of Two New Tax Agencies under AB 102 and AB 131,” Journal of Multistate Taxation and Incentives (January 2018)
    • “One Can Certainly Hope, Farewell 2017, Hello 2018!,” State Tax Notes (December 18, 2017)
    • "Blazing a Trial For More Local Taxes By Ballot Initiative," Law 360 September 8, 2017
    • “Eye of the Beholder, Sins of the States,” State Tax Notes (July 3, 2017)
    • “Imposing Documentary Transfer Taxes in California after Ardmore,” Law 360 (July 7, 2017)
    • “Some Observations on Gross Receipts Taxes,” Journal of Multistate Taxation and Incentives (July 2017)
    • “Taxes, Fees, and ‘Something Else': California's Morning Star Decision,” State Tax Notes (June 12, 2017)
    • “California Pass-Through Entity Navigator,” Bloomberg BNA (2017-present)
    • “Water's-Edge Issues to Watch,” State Tax Notes (April 17, 2017)
    • “State Tax Matters for Foreign Corporations,” The Tax Executive (March 2017)
    • "Expanding the Water's Edge: Four Trends to Watch in International Issues in State Taxation" Eversheds Sutherland’s Partnering Perspectives (Spring 2017)
    • “Nortel, Lucent, and California Treatment of Embedded Software; California Cannabis Coalition and the Right to Vote on California Local Taxes; and Ardmore and the Application of the California Documentary Transfer Tax to Changes of Ownership or Control, in Board Sheds Light on Dark Horse Issues of 2017,” State Tax Notes (January 23, 2017)
    • “Nortel, Lucent, and Taxing Embedded Software in California Under a Technology Transfer Agreement,” Journal of Multistate Taxation and Incentives (January 2017)
    • “California Corporation Income Tax Portfolio,” Bloomberg BNA, (2016-present)
    • “Economic Nexus and the Water's-Edge Election in California,” Tax Law 360 & California Law360 (September 23, 2016)
    • “Four Trends to Watch in International Issues in State Taxation,” Journal of Multistate Taxation and Incentives (July 2016). Reprinted in Journal of International Taxation (November 2016)
    • “The Fate of the Multistate Tax Compact Election,” Law 360 (January 27, 2016)
    • “California's New Market Sourcing Rules for Marketable Securities, Asset Managers, Interest, Dividends and Goodwill,” Journal of Multistate Taxation and Incentives (January, 2016)
    • “California Governor Signs Bill Limiting Cities and Counties Use of Sales/Use Tax Agreements,” Morrison & Foerster Client Alert (October 14, 2015)
    • “Throwback Sales Issues in California,” State Tax Notes (October 12, 2015)
    • “California Enacts Federal Conformity Bill,” Morrison & Foerster Client Alert (October 7, 2015)
    • “FTB Releases Plans for May Department Stores Interest Computation Adjustments,” Morrison & Foerster Client Alert (August 6, 2015)
    • “California FTB Considers Revisions to Combination Regulations for Mixed Financial and Non-Financial Reporting Groups,” Journal of Multistate Taxation and Incentives (July 2015)
    • “Economic Substance and Related Issues in California Income Taxation,” State Tax Notes (March 2, 2015)
  • Presentations
    • “Apportionment: Deep Dive into Determining Where the Benefit is Received,” 2019 American Bar Association/Institute for Professionals in Taxation Advanced State Income, Sales/Use & Property Tax Seminars, March 2019, New Orleans, LA.
    • "Navigating Sales/Use Tax Protests and Appeals," 2018 Institute for Professionals in Taxation’s Annual Conference, June 2018, Vancouver, Canada.
    • “Challenging Assessments and Managing Protests,” Tax Executives Institute Audits & Appeals Seminar, State Tax Controversy, May 2018, New Orleans, LA.
    • “The Insider’s Guide to New Tax Dispute Resolution Forums,” ABA/IPT Advanced Income Tax Seminar, March 2018, New Orleans, LA.
    • “State Tax Developments in California and Other Western States,” Tax Executives Institute, Dallas Chapter, January 2018, Dallas, TX.
    • “California’s Department of Taxation and Fee Administration and Office of Tax Appeals: What Now?” TEI/IPT Silicon Valley SALT Day, December 2017, San Jose, CA.
    • “State & Local Tax Issues,” Mergers & Acquisitions, the Lifecycle of a Transaction: An Interdisciplinary Approach, TEI, November 2017, Boston, MA.
    • “California’s State Board of Equalization is Being Substantially Replaced,” COST 48thAnnual Meeting, October 2017, Orlando FL
    • “Through the Looking Glass: The Significance of the MTC from the Outside,” Multistate Tax Commission 50thAnnual Conference, August 2017, Louisville KY.
    • “Comprehensive Corporate Income Tax,” U.C Davis King School of Law, June 2017.
    • “Resolution Through the Courts,” Tax Executives Institute Audits & Appeals Seminar, May 2017, Seattle, WA.
    • “Current California and Western State Tax Developments,” Tax Executives Institute, Philadelphia Chapter, April 2017, Philadelphia, PA
    • “The Rise of Gross Receipts Taxes,” ABA/IPT Advanced Income Tax Seminar, March 2017, New Orleans, LA.
    • “Understanding California’s Technology Transfer Act Provisions,” COST Sales Tax Conference, February, 2017, San Antonio, TX.
    • “Current State Tax Developments in California and Other Western States,” Tax Executives Institute, Dallas Chapter, January 2017, Dallas, TX.
    • “Current State Tax Litigation Every SALT Professional Should Know About,” Tax Executives Institute, Houston Chapter, State and Local Tax Roundtable, October 2016, Houston, TX.
    • “'Welcome to Nevada!’ California Residency and Sourcing Issues,” Parasol Foundation, July 2016, Incline Village, NV.
    • “Current State Tax Developments in California and Other Western States,” Tax Executives Institute, Denver Chapter, May 2016, Denver, CO.
    • “Current California and Western State Tax Developments,” Tax Executives Institute, Philadelphia Chapter, April 2016, Philadelphia, PA.
    • “Federal and International Issues Affecting SALT, Both for Inbound and Outbound Taxpayers,” ABA/IPT Advanced Income Tax Seminar, March 2016, New Orleans, LA.
    • “Section 18 and the Constitutional Parameters of Alternative Apportionment,” ABA/IPT Advanced Income Tax Seminar, February 2016, New Orleans, LA.
    • “Current State Tax Developments in California and Other Western States,” Tax Executives Institute, Dallas Chapter, January 2016, Dallas, TX.
    • “State Tax Cases, Issues, and Policies to Watch,” COST North Atlantic Regional State Tax Seminar, November 2015, New York, NY.
    • “Gone Girl, Inc., California and Federal Corporate Tax Reform.” Annual Meeting of the California Tax Bar & California Tax Policy Conference, November 2015, La Jolla, CA.
    • “West Coast Update,” Morrison & Foerster LLP, State & Local Tax West Coast Update, June 2015, San Francisco, CA.
    • “Current California and Western State Tax Developments,” Tax Executives Institute, Philadelphia Chapter, April 2015, Philadelphia, PA.
    • “Developments in California, Oregon and Arizona,” and “Six Troublesome Aspects of California Corporate Tax Transactions,” Morrison & Foerster LLP, East Coast Update, April 2015, New York, New York.
    • “Current California Tax Developments,” Tax Executives Institute, Dallas Chapter, January 2015, Dallas, TX.
  • Books
    • Chapter 5: Current California Tax Developments (2012) New York University Institute on State and Local Taxation
    • Chapter 5: Current California Tax Developments (2010) New York University Institute on State and Local Taxation
    • Chapter 2: Current California Tax Developments (2008) New York University Institute on State and Local Taxation
    • Chapter 2: Current California Tax Developments (2006) New York University Institute on State and Local Taxation

Education

  • LL.M., Taxation, University of the Pacific, McGeorge School of Law, 1986

    J.D., University of the Pacific, McGeorge School of Law, 1978
    Moot Court Honors Board

    M.A., California State University, Dominguez Hills, 2008

    A.B., History, Occidental College, 1974

Admissions

  • California

Courts

  • U.S. District Court for the Eastern District of California

    U.S. Court of Appeals for the Ninth Circuit

    U.S. Supreme Court

    U.S. Tax Court