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Jeff Phang

Counsel
Sacramento

Counsel, Sacramento

T: +1.916.329.4723
T: +1.916.329.4723

Areas of Focus

Jeffrey Phang focuses his practice on state and local tax controversy.

Jeff advises clients with state tax and local income, franchise, and sales and use tax issues. He focuses primarily on tax controversy including voluntary disclosure agreements, audit defense, protest, settlement negotiation and appeals proceedings. Jeff also advises on mergers and acquisition state and local tax diligence for a diverse range of businesses.

Representative Experience

  • Represented a technology client before the California Franchise Tax Board, State Board of Equalization, and Office of Tax Appeals, and secured a favorable closing agreement related to an apportionment dispute.
  • Assisted a grocery retailer with a multiyear unitary combination dispute and achieved a favorable settlement resolution with the California Franchise Tax Board.
  • Represented aerospace client before the California Franchise Tax Board and secured favorable settlement related to sourcing dispute.

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  • Represented asset management client in dispute regarding qualified investment partnership status.
  • Assisted investors with state sourcing issues related to disposition of business interests.

Professional Highlights

Honors & Awards

  • Recognized by Chambers USA for Tax: State & Local (2025)

Publications

  • “California Trial Court Finalizes Ruling for Taxpayer in Smithfield Apportionment Dispute,” SeeSALT, May 5, 2026. Coauthor.
  • “Billion-Dollar Question: California Initiative Targets the Ultra-Wealthy with One-Time Tax,” SeeSALT, October 28, 2025. Coauthor.

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  • “Sourced and Settled: California FTB Finalizes its Long-Awaited Market-Sourcing Regulation, Applicable to Tax Year 2026 and Beyond,” SeeSALT, September 19, 2025. Coauthor.
  • “Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals,” SeeSALT, August 21, 2025. Coauthor.
  • “California Legislature Advances Broad Federal Tax Conformity Bill (SB 711),” SeeSALT, May 28, 2025. Coauthor.
  • “California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment,” Pillsbury client alert, February 20, 2025. Coauthor.
  • “California OTA Denies Credit for NYC Business Taxes in Precedential Opinion,” SeeSALT, December 9, 2024. Coauthor.
  • “California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16,” SeeSALT, October 7, 2024. Coauthor.
  • “California’s 2024–2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization,” SeeSALT, June 5, 2024. Coauthor.
  • “Reminder: ‘Gross’ Does Not Mean ‘Net’ – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor,” SeeSALT, April 4, 2024. Coauthor.
  • “Winter Storm Relief – California’s 2024 Extended Deadlines to File and Pay Taxes,” SeeSALT, March 20, 2024. Coauthor.
  • “No Day Off for Buehler: California Sources Gain from Sale of Intangible to Domicile and Denies Other State Tax Credit,” SeeSALT, May 17, 2023. Coauthor.
  • “UPDATE: California Adds New Counties, Further Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT, March 8, 2023. Coauthor.
  • “California Extends Deadlines to File and Pay Taxes for Businesses and Individuals Affected by Severe Winter Storms,” SeeSALT, January 23, 2023. Coauthor.
  • “The California Franchise Tax Board Fails to Follow the Order of Its Market-Based Sourcing Cascading Rules,” SeeSALT, October 24, 2022. Coauthor.
  • “The Curious First Meeting of the MTC’s Model Receipts Sourcing Regulations Work Group,” Pillsbury client alert, October 18, 2022. Coauthor.
  • “California Court Holds Nonresidents’ Pass-through Income from Intangibles Is Taxable if It Is Classified as Business Income at the Entity Level,” SeeSALT, June 9, 2022. Coauthor.
  • “California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by 2020 Legislation,” SeeSALT, February 10, 2022. Coauthor.
  • “How to Be Reasonable When Reasonably Approximating the Market: Part II,” Tax Notes State, December 20, 2021. Coauthor.
  • “California Governor Vetoes Sales Tax Bill Seeking to Require Large Online Retailers to File Informational Reports Detailing Sales by Destination,” SeeSALT, October 7, 2021. Coauthor.
  • “Taxpayer Files Court Action Challenging California’s Proposition 39 (2012) and its Mandatory Single-Sales Factor Apportionment Formula,” SeeSALT, September 20, 2021. Coauthor.
  • Speaking Engagements

    • “Mental Wellness in Early Legal Practice,” Sacramento Young Tax Lawyers, March 2026, Sacramento, Calif.

    • “Credit Where Credit’s Due: California’s Evolving Other State Tax Credit,” 2025 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2025, San Diego, Calif.

    • “Legislation and Regulations,” COST California Corporate Income Tax Webinar, June 2025, Webinar.
    • “Reasonable Cause Standard – How Reasonable Is It?” 2024 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2024, Anaheim, Calif.
    • “Sourcing Income from Passthrough Entities & Developments Since Metropoulos,” 2023 Annual Meeting of the Tax Bar and Tax Policy Conference, November 2023, Palm Springs, Calif.
    • “Top Corporate Income Tax Cases and Trends,” TEI Chicago Chapter Virtual State Income Tax Program,” December 2021, Webinar.
    • “Recent Developments in California Income Tax Apportionment and Sourcing Law,” California Lawyers Association, September 2021, Webinar.

Education

  • J.D., Seton Hall University School of Law, 2013
    cum laude

    B.S., University of California, Davis, 2010
    Managerial Economics, magna cum laude

Admissions

  • California

Courts

  • Ninth Circuit Court of Appeals

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