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Tax Attorney in Chino Hills, California

California-admitted attorneys handling IRS, FTB, CDTFA Diamond Bar, EDD, and San Bernardino County Assessment Appeals Board matters for Chino Hills, Carbon Canyon, and the 91709 ZIP. We represent the Indian-American, Chinese-American, and Korean-American households on FBAR, Form 8938, and PFIC compliance, Vellano and Sleepy Hollow Estates HNW estates, Carbon Canyon equestrian §170(h) conservation work, Mello-Roos CFD analysis on §164 deduction splits, tri-county 71/57/91 commuter residency, and the LDS clergy §107 housing-allowance and §170(f)(8) tithe-substantiation pattern.

Parham Khorsandi, Esq., Cal Bar #266658 — verify on calbar.ca.gov

Key Takeaways for Chino Hills Taxpayers

  • We are California-admitted in every relevant forum — federal IRS work, FTB, CDTFA, EDD, the California Office of Tax Appeals, the San Bernardino County Assessment Appeals Board, and California Superior Court. No "refer to local counsel" hand-off, no second-firm referral chain.
  • Chino Hills-specific work: Indian-American, Chinese-American, and Korean-American FBAR / Form 8938 / Form 8621 PFIC packages (ICICI, HDFC, SBI, Axis, Bank of China, ICBC, CCB, China Merchants, KEB Hana, Woori, Shinhan, KB Kookmin); Vellano, Sleepy Hollow Estates, Las Lomas, and Avila Hills HNW estate planning under §6166 and §1014; Mello-Roos CFD §53311 special-tax deductibility analysis; Carbon Canyon equestrian §170(h) conservation-easement work; LDS clergy §107 housing-allowance and §170(f)(8) tithe substantiation; tri-county commuter R&TC §17041 / §17951 residency analysis.
  • CDTFA closed West Covina and opened the new Diamond Bar district office at 21680 Gateway Center Drive Suite 200 on March 18, 2024 — all Chino Hills sales-tax audit work routes through Diamond Bar now. We file CDTFA Form 392 PoA and step in front of the Diamond Bar auditor.
  • Federal CSED is 10 years (IRC §6502); California FTB CSED is 20 years (R&TC §19255). State collection runs twice as long — strategy has to account for both clocks.
  • Free, confidential consultation: (800) 883-8301. Past results referenced below carry the standard no-guarantee disclaimer.

Victory Tax Lawyers represents Chino Hills individuals and businesses in front of the IRS, the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, the Office of Tax Appeals, and the San Bernardino County Assessment Appeals Board. We are a California-headquartered firm with both Managing Attorneys admitted to the State Bar of California and the United States Tax Court. This page covers what we handle for Chino Hills, where the relevant agency offices and courthouses sit, and the issues that come up specifically in the 91709 ZIP — from the deep Indian-American, Chinese-American, and Korean-American FBAR pattern, to Mello-Roos CFD special-tax analysis in Vellano and Sleepy Hollow Estates, to HNW estate planning in the $20-40 million range, to Carbon Canyon equestrian conservation work.

Firm Credentials

5.0★

72 Google reviews aggregate

2,000+ cases

Federal and California resolutions

$100M+ in relief

Cumulative client outcomes

CA-admitted

Parham Khorsandi #266658 & Amir Boroumand #269570

Past results are not a guarantee of future outcomes. Every case turns on its own facts and applicable law.

Last Reviewed: by Parham Khorsandi, Esq.

Free, confidential consultation: (800) 883-8301

If you are a Chino Hills taxpayer facing IRS collection in the 91709 ZIP, an FTB Notice of Proposed Assessment under R&TC §19031, a CDTFA sales-tax audit now routed through the Diamond Bar district office at 21680 Gateway Center Drive Suite 200, an EDD Form DE 1870 worker-classification notice, a San Bernardino County supplemental property-tax assessment after a Vellano, Sleepy Hollow Estates, Las Lomas, Avila Hills, or Carbon Canyon transfer, an FBAR or Form 8938 disclosure question on Indian, Chinese, Korean, or other overseas accounts, or a City of Chino Hills business-license matter — this is the work we handle every day. Indian-American households with NRE / NRO / FCNR accounts at ICICI, HDFC, SBI, Axis, or Bank of Baroda, Chinese-American households with Bank of China, ICBC, CCB, China Merchants, or Ping An wealth-management products, Korean-American households with KEB Hana, Woori, Shinhan, KB Kookmin, or IBK accounts, HNW Vellano / Sleepy Hollow / Las Lomas estates planning under §6166, Carbon Canyon equestrian and conservation-easement clients, LDS clergy households running the §107 housing allowance, and tri-county commuter residency questions all sit inside our practice.

Firm Results to Date

$100M+

in cumulative tax relief for our clients

2,000+

federal and state matters resolved

5.0★ / 72

Google reviews aggregate

Past results are not a guarantee of future outcomes. Individual case results depend on the facts and applicable law.

Why California-Home-State Representation Matters in Chino Hills

Many out-of-state tax-resolution firms market into the Inland Empire and Chino Hills, take a retainer for the IRS half of a case, and then refer the state-court half to a separate firm. That introduces a hand-off cost and a coordination gap right when a Chino Hills client needs the federal and state strategies aligned. Victory Tax Lawyers is California-headquartered. Both Managing Attorneys are admitted to the State Bar of California, the United States Tax Court, and the United States District Court for the Central District of California. We handle the federal side (IRS Appeals, Tax Court, audit reconsideration, Offer in Compromise under IRC §7122, Installment Agreement under IRC §6159, Collection Due Process under IRC §6320/§6330) and the state side (FTB administrative protest under R&TC §19044, FTB Settlement Bureau, CDTFA petition for redetermination, EDD petition, OTA appeal under R&TC §19324, Superior Court refund actions under R&TC §19382 and §19385, Court of Appeal review) from the same desk.

Federal §7525 attorney-client privilege applies to our IRS work. State Bar of California Rule 1.6 confidentiality covers everything we discuss. When a Chino Hills client needs both an Offer in Compromise with the IRS and an FTB Settlement Bureau submission for the parallel state liability, we coordinate the two so a federal accepted-OIC doesn't trigger an unexpected state deficiency on the discharged federal debt, and so a CDTFA petition for redetermination doesn't sit unfiled past the 30-day window while the IRS work is pending.

For Chino Hills households with FBAR or Form 8938 exposure on overseas accounts in India, China, Korea, the Philippines, Vietnam, Hong Kong, Taiwan, Mexico, or anywhere else, the federal §6038D reporting and the FinCEN 31 USC §5314 reporting run on parallel tracks with separate penalty regimes. Streamlined Domestic Offshore Procedure for non-willful non-compliance, Streamlined Foreign Offshore Procedure for taxpayers physically outside the U.S., and the IRS Criminal Investigation Voluntary Disclosure Practice for willful exposure each have their own thresholds and outcomes. We package the right track for the facts and run the federal and California sides together.

Your Rights as a Chino Hills California Taxpayer

IRS Taxpayer Bill of Rights

Codified at IRC §7803(a)(3). Ten rights including the right to be informed, the right to quality service, the right to challenge the IRS's position and be heard, the right to appeal an IRS decision in an independent forum, and the right to retain representation. You can fire a tax-resolution firm at any point and hire counsel; the IRS Office of Appeals is required to recognize a Form 2848 PoA within 24-48 hours of filing.

California Taxpayers' Bill of Rights

Codified at R&TC §21001 et seq. for FTB and §7080 et seq. for CDTFA. Includes the right to a clear explanation of any liability, the right to be represented, the right to confidentiality of return information, the right to plain-language notices, and the right to recover reasonable attorney's fees under R&TC §21013 in certain successful actions.

Prop 13 & Prop 19 Protections

Cal. Const. Art. XIIIA §1 caps the property-tax ad valorem rate at 1% of factored base-year value with a 2% annual inflation cap. Proposition 19 (effective February 16, 2021) preserves the parent-child base-value transfer only for a principal residence the child makes their own primary residence within one year of transfer, with a $1 million indexed ceiling above the parent's factored base.

Right to a Hearing

Federal: CDP hearing under IRC §6320 (lien) or §6330 (levy), 30 days to file Form 12153. State: FTB Notice of Proposed Assessment under R&TC §19031, 60 days to protest in writing. OTA petition: 30 days from FTB Notice of Action under R&TC §19324. Property tax: Application for Changed Assessment within 60 days of supplemental notice OR between July 2 and November 30 for the regular roll at the San Bernardino County Clerk of the Board.

How Victory Tax Lawyers Helps Chino Hills Taxpayers

Offer in Compromise — IRC §7122 + R&TC §19443

Federal OIC on Form 656 with Form 433-A(OIC) or 433-B(OIC), plus parallel state OIC with FTB Form 4905 PIT or BE. We package both so an accepted federal offer doesn't create a cancellation-of-debt issue on the state side, and so the FTB's separate Reasonable Collection Potential math doesn't undercut the federal submission.

Installment Agreement — IRC §6159 + FTB §19008

Streamlined and partial-pay installment agreements with the IRS, with parallel FTB Installment Agreement through FTB Web Pay. We structure both to fit a single combined monthly outlay so a Chino Hills household isn't double-budgeting against the federal and state collection departments.

Lien Release — IRC §6325 + R&TC §7170

Federal Notice of Federal Tax Lien withdrawal, subordination, or release. California State Tax Lien recorded under R&TC §7170 with the San Bernardino County Recorder — we handle the satisfaction filing with the same office, plus Vellano, Carbon Canyon, and Las Lomas refinance subordinations under §6325(d).

Levy & Wage Garnishment Release — IRC §6343 + R&TC §19021

IRS levy release on bank accounts, wages, and accounts receivable. California FTB wage levy (Earnings Withholding Order for Taxes, EWOT) release through the local sheriff or directly with the FTB Collections Bureau. Federal 21-day bank hold, FTB 10-business-day hold — timing decisive on professional-services receivables and HNW investment accounts.

Audit Defense — IRS + FTB + CDTFA + EDD

Field, office, and correspondence audits with the IRS; FTB residency audits under R&TC §17014 and §17951 source audits on tri-county commuter wages; CDTFA sales/use audits routed through the Diamond Bar district office at 21680 Gateway Center Drive; EDD Form DE 1870 worker-classification audits.

Penalty Abatement — IRC §6651/§6662 + CA reasonable cause

First-Time Abate, reasonable-cause statements, IRC §6404 administrative-error claims, and FTB R&TC §19131/§19132 reasonable-cause waivers. Documented illness, fire, theft, and natural-disaster grounds — the 2008 Triangle Complex Fire that ran through Carbon Canyon and into Chino Hills State Park is one of the recognized reasonable-cause anchors for older Chino Hills filers.

FBAR / Form 8938 / Form 8621 — 31 USC §5314 + IRC §6038D + §1296

Streamlined Domestic Offshore Procedure for non-willful disclosure (3 years of amended returns, 6 years of FBARs, Form 14654 certification, 5% Title 26 miscellaneous offshore penalty), Streamlined Foreign Offshore for taxpayers outside the U.S. (no Title 26 penalty), Voluntary Disclosure Practice (IRS-CI) for willful exposure. PFIC §1296 mark-to-market election year over year on Indian, Chinese, and Korean mutual-fund / structured-product holdings.

HNW Estate & Gift — §2010 / §6166 / §1014 / §170(h)

Federal estate-tax planning at the $13.99M (2025) / $7M (post-2026 sunset) thresholds, §6166 14-year installment for closely-held business interests, §1014 stepped-up basis coordination, §170(h) conservation-easement work on Carbon Canyon equestrian acreage, family-limited-partnership §2036 retained-interest defense, Form 706 audit defense.

12 Tax Issues We Handle for Chino Hills Clients

1. Indian-American FBAR / Form 8938 / PFIC (ICICI, HDFC, SBI, Axis)

NRE / NRO / FCNR accounts, Indian mutual-fund SIPs as PFICs under IRC §1296 / §1297, demat accounts, FBAR FinCEN 114 plus Form 8938 plus Form 1116 foreign-tax-credit coordination. Streamlined Domestic Offshore packaging for non-willful disclosure.

2. Chinese-American FBAR / Form 8938 / PFIC (Bank of China, ICBC, CCB, China Merchants)

Bank of China, ICBC, China Construction Bank, China Merchants Bank deposits and wealth-management products (lǐcái chǎnpǐn) testing as PFICs, insurance-linked savings from PICC / Ping An / China Life, 70-year leasehold property reporting on Form 8938, §988 RMB currency-gain timing.

3. Korean-American FBAR / Form 8938 / PFIC (KEB Hana, Woori, Shinhan)

KEB Hana, Woori, Shinhan, KB Kookmin, IBK accounts, Korean ISA and tax-deferred savings, U.S.-Korea 1979 income tax treaty residency tie-breaker analysis. Bank of Hope (NASDAQ: HOPE) is a U.S. bank — not on FBAR.

4. Vellano / Sleepy Hollow / Las Lomas / Avila Mello-Roos analysis

Streets & Highways Code §53311 CFD special taxes adding $3K-$9K/year per parcel for 25-40 years. §164 SALT cap interaction, Treas. Reg. §1.164-4(b)(1)(ii) capital-vs-operations split, federal deductibility analysis, and §263A capitalization for commercial parcels.

5. HNW estate planning — $20-40M Chino Hills households

§2010(c) federal exemption ($13.99M 2025, sunset 2026 to ~$7M), §6166 14-year deferral on closely-held business interest exceeding 35% of AGE, §1014 stepped-up basis, GRATs under §2702, IDGT installment sales, family-limited-partnership valuation discounts, §2036 defense.

6. Carbon Canyon equestrian §170(h) conservation easement

§170(h)(2)(C) perpetual restriction, §170(h)(3) qualified holder (Wildlife Land Trust, Hills For Everyone), Treas. Reg. §1.170A-14(h)(3) before-and-after FMV appraisal, Form 8283 Section B reporting. Distinct from the Notice 2017-10 Listed-Transaction syndicated-easement audit campaign.

7. LDS clergy §107 housing allowance & §170(f)(8) tithe

§107 minister-of-the-gospel housing exclusion (Gaylor v. Mnuchin 7th Cir. 2019 survival), §1402(e) SECA opt-out election analysis. §170(f)(8) contemporaneous written acknowledgment audit defense for the Chino Hills LDS Stake and the annual tithing statement.

8. Tri-county commuter residency & departing-resident

R&TC §17041 / §17951 nonresident allocation for the 71/57/91 commute to Diamond Bar, LA County, San Bernardino, Riverside, OC. Stephen Bragg (2003-SBE-002) and Bindley (2018) closer-connection factors for Chino Hills → Las Vegas / Henderson / Phoenix / Austin moves.

9. CDTFA Diamond Bar sales-tax audit defense

Post-March 18, 2024 CDTFA Diamond Bar district office at 21680 Gateway Center Drive Suite 200 (West Covina closed). Crossroads at Chino Hills and Shoppes at Chino Hills retail / restaurant POS reconciliation, online-retail Wayfair §6203 use tax, R&TC §6481 test-period methodology.

10. Prop 19 Vellano / Carbon Canyon inheritance reassessment

Cal. Const. Art. XIIIA §2 parent-child exclusion now requires primary residence within 12 months and a $1M indexed ceiling on excess FMV. Vellano / Carbon Canyon / Las Lomas inherited estates — 60-day AAB filing window at the San Bernardino County Clerk of the Board, 385 N Arrowhead.

11. RSU / ISO / NSO — LA + OC tech & finance employer

Chino Hills professionals at LA, OC, and IE employers with concentrated stock-comp positions. §83(b) basis trap on RSAs (not RSUs), §56(b)(3) AMT preference on ISO exercise, §53 minimum-tax credit recovery, §422 disqualifying-disposition analysis on ISO sales inside 12/24 months.

12. Chino USD / Chino Valley USD payroll + CalSTRS

Teachers in CalSTRS defined-benefit plus DBS / Cash Balance, district §403(b) (Voya, AIG, Equitable, TIAA, Vanguard) and §457(b) through CalPERS Supplemental Income. Social Security Fairness Act WEP/GPO repeal and CalSTRS service-credit-purchase tax analysis.

9 Common Causes of Chino Hills Tax Debt

  1. Unreported foreign accounts crossing the $10,000 FBAR aggregate. Chino Hills Indian-American, Chinese-American, Korean-American, Filipino-American, and Vietnamese-American households often carry NRE, NRO, FCNR, RMB, KRW, peso, and dong accounts that aggregate over $10,000 and were never reported on FinCEN 114 or Form 8938.
  2. PFIC default §1291 excess-distribution regime on overseas mutual funds. ICICI Prudential, HDFC, SBI Mutual Fund, China AMC, Korean ETFs, and similar fund holdings hit the punitive throwback-and-interest §1291 calculation when no §1296 mark-to-market or §1295 QEF election is on file.
  3. Mello-Roos CFD special-tax confusion on the SALT deduction. Vellano, Sleepy Hollow Estates, Las Lomas, and Avila Hills owners claim the full property tax bill on Schedule A and the IRS picks up the non-ad-valorem CFD portion.
  4. Tri-county commuter wage misallocation. Chino Hills residents working in Diamond Bar, LA, San Bernardino, Riverside, or OC employer locations with multi-state W-2 lines and incomplete CA Schedule CA reconciliation.
  5. HNW Vellano / Sleepy Hollow / Las Lomas estate & gift slippage. Missed annual exclusion gifting under §2503(b), missed §2010(c)(5) portability filing on the deceased spouse, GRAT term-failure dragging the asset back into the estate under §2036.
  6. Prop 19 inheritance shock on Vellano / Carbon Canyon homes. Children inheriting Vellano, Sleepy Hollow, or Carbon Canyon estates who don't move in within 12 months get full FMV reassessment plus the $1M excess on the parent's base value.
  7. Reasonable-compensation S-corp audits. Chino Hills professionals (medical, dental, legal, consulting) operating S-corps with low W-2 to high K-1 splits hit the IRS S-corp employment-tax campaign.
  8. Stock-comp AMT trap on ISO exercise. Chino Hills tech and finance employees exercising ISOs and holding without modeling the §56(b)(3) AMT preference get a six- or seven-figure surprise on April 15.
  9. FTB departing-resident NPA after move to NV / AZ / TX. Households retaining the Chino Hills home, utilities, vehicle registration, and Chino Valley USD enrollment after a Las Vegas or Phoenix move fail the Stephen Bragg closer-connection analysis.

8 Federal & California Liability Pairings

Income tax

Federal IRC Subtitle A. California R&TC §17041 (top marginal 13.3% including 1% mental-health surcharge over $1M). California-source allocation under R&TC §17951 for the tri-county commute.

Self-employment / SE tax

Federal IRC §1401 (15.3% up to SS wage base, 2.9% Medicare uncapped, plus 0.9% Additional Medicare). California Schedule CA conforms. SECA §1402(e) opt-out for ordained clergy.

Employment / payroll tax

Federal IRC §3101/§3111 (FICA), §3301 (FUTA), §3121(q) (tip catch-up). California UIC §13020 (CA UI), §1088 (DE 9). EDD enforces. §6672 trust-fund recovery on responsible individuals.

Sales & use tax

No federal sales tax. California R&TC §6051 et seq. CDTFA administered. Chino Hills combined rate currently 7.75% (state 6%, San Bernardino County district 1.5%, base 0.25%). Diamond Bar CDTFA district office.

Corporate franchise tax

Federal IRC Subtitle A Subchapter C. California R&TC §23151 (8.84% flat C-corp), §23802 (1.5% S-corp), §17942 ($800 LLC tax + tiered fee under FTB 3536/3537).

Property tax + Mello-Roos

No federal real property tax. California Cal. Const. Art. XIIIA §1 (Prop 13). R&TC §75-§75.80 (supplemental). R&TC §1603-1611 (AAB appeals). Streets & Highways Code §53311 (Mello-Roos CFD) on Vellano, Sleepy Hollow, Las Lomas, Avila Hills.

Estate & gift tax

Federal IRC Subtitle B. §2010(c) unified credit ($13.99M 2025, sunset 2026 to ~$7M). §2503(b) annual exclusion ($19,000 2025). §6166 14-year installment for closely-held business. No California estate or gift tax.

Information-reporting & foreign-account penalties

Federal IRC §6721/§6722 (1099 / W-2). California R&TC §19133.5 mirror. FBAR 31 USC §5314 + 31 CFR §1010.350 (non-willful ~$10K/account/year inflation-adjusted, willful 50% of balance/year). Form 8938 IRC §6038D ($10K, up to $50K). Form 8621 PFIC reporting under §1298(f).

What Resolution Looks Like

Immediate stabilization

IRS levy release within 24-72 hours on documented hardship. FTB EWOT release on the same timeline. Bank-account hold released by Form 668-A revocation. Form 2848 PoA filed so agency calls stop coming to your Chino Hills address.

Path to resolution

Offer in Compromise, partial-pay installment, currently-not-collectible (IRS Form 433-F), abatement of accuracy-related and failure-to-file penalties, audit reconsideration under IRM 4.13. Parallel FTB and CDTFA tracks where applicable. Streamlined Domestic Offshore for FBAR / Form 8938 non-willful disclosure.

Forward-facing compliance

Quarterly estimated-tax planning for HNW Chino Hills households, withholding adjustments for tri-county commuter wages, entity selection for Schedule C professionals (S-corp election under §1362), §1296 PFIC mark-to-market elections going forward, and §6166 estate-tax installment monitoring.

Settlement Range Examples

Resolution type Original liability Settled amount Mechanism
Installment Agreement$138,296$25/monthPartial-pay IA under IRC §6159 with CSED runout
Partial-Pay Installment$126,489$50/monthForm 433-A documented hardship
Installment Agreement$128,206$25/monthStreamlined IA with CSED runout
Partial-Pay Installment$116,451$50/monthForm 433-B business expense substantiation
Installment Agreement$152,296$25/monthIRC §6159 streamlined IA

Past results are not a guarantee of future outcomes. Settlement amounts depend on the taxpayer's reasonable collection potential, available equity in assets, allowable expenses under IRS Collection Financial Standards, and the specific facts of the case. No outcome is guaranteed.

Why Choose Victory Tax Lawyers for Chino Hills Matters

  • California-admitted in every CA forum. State Bar of California, US Tax Court, US District Court Central District of California, US Court of Appeals Ninth Circuit. We don't refer Chino Hills state-side work to a separate firm.
  • Los Angeles-based main office, Chino Hills-ready. 1100 S Robertson Blvd, Los Angeles — 45-50 miles west of Chino Hills on the 60 freeway. We attend IRS Taxpayer Assistance Center appointments at 290 N D Street San Bernardino (or 300 N Los Angeles for clients on the LA side of the 71 corridor), CDTFA hearings at the Diamond Bar district office, US District Court hearings at the George E. Brown, Jr. Courthouse in Riverside, US Tax Court trial sessions in Los Angeles, and San Bernardino County Assessment Appeals Board hearings at 385 N Arrowhead Avenue.
  • 72 Google reviews aggregating 5.0 stars. Verifiable on the firm's Google Business Profile.
  • Dual-attorney review. Cases are worked by an attorney and reviewed by the other Managing Attorney before any submission to a federal or state agency.
  • Federal §7525 attorney-client privilege. Distinct from the CPA federally-authorized-tax-practitioner privilege, which doesn't apply to criminal matters or in state court.
  • Multi-language access. We've handled FBAR / Form 8938 / PFIC packages for Chino Hills Indian-American, Chinese-American (Mandarin and Cantonese), Korean-American, Filipino-American, and Vietnamese-American households. Translation support coordinated for client communications where the underlying account documents are in Hindi, Mandarin, Korean, Tagalog, or Vietnamese.

Our 7-Step Process for Chino Hills Clients

  1. Free confidential consultation. Call (800) 883-8301. We discuss the matter, the agencies involved, and a fee estimate before you sign anything.
  2. Engagement & Form 2848 / FTB 3520. You sign the engagement agreement and the federal and state powers of attorney. Within 48 hours we are recognized representatives and the IRS / FTB / CDTFA / EDD stops contacting you directly.
  3. Transcript & record pull. Full federal account transcripts via e-Services, FTB account transcripts via MyFTB Tax Professional, CDTFA history via CDTFA Online Services, EDD via e-Services for Business. For FBAR / Form 8938 cases we pull foreign-account statements and translate where needed.
  4. Analysis & strategy. We identify the path: OIC, IA, audit reconsideration, CDP, FTB Settlement Bureau, OTA appeal, Assessment Appeals Board application, Streamlined Domestic Offshore, Voluntary Disclosure Practice, §6166 estate-tax installment, or a combined federal-state plan.
  5. Submission & representation. Form 656, Form 433-A(OIC) or 433-B(OIC), FTB Form 4905, San Bernardino County Application for Changed Assessment, OTA petition, Streamlined package with Form 14654 certification, or whatever the matter requires. We are the contact, not you.
  6. Negotiation. We work the assigned Revenue Officer, FTB Settlement Bureau attorney, CDTFA Diamond Bar hearing officer, EDD petition hearing, AAB hearing officer, or Estate & Gift Tax Examiner through resolution.
  7. Closing & forward compliance. Closing letter from the agency, removal of liens and levies, current-year withholding and estimated-tax setup, §1296 PFIC mark-to-market election framework, and a calendar for any monitoring obligations.

Federal & California Collection Statute Warning

Federal CSED — IRC §6502: The IRS has 10 years from the date of assessment to collect a tax liability. After that, the debt expires by operation of law. The CSED tolls during bankruptcy, while an Offer in Compromise is pending, during CDP appeal, while the taxpayer is out of the country for six months or more, and under certain Form 900 waivers.

California CSED — R&TC §19255: The FTB has 20 years from the date of assessment to collect — twice the federal period. CDTFA collections run under a similar 10-year statute from final determination under R&TC §6757. The 20-year California number surprises Chino Hills taxpayers who assume state collection follows the federal rule. We model the federal and state CSEDs against any proposed settlement so the strategy doesn't accidentally restart the state clock or surrender a year of unused federal expiration. For FBAR penalties the assessment statute under 31 USC §5321(b)(1) is 6 years from the FBAR due date, and the collection statute under 31 USC §3716 / §3720E runs separately — we calendar all three.

Chino Hills Venue & Government-Entity Directory

Federal — IRS Taxpayer Assistance Center

Two options: IRS TAC at 290 N D Street, San Bernardino, CA 92401 (about 26 miles east on the 60/215) or IRS TAC at the LA Federal Building, 300 N Los Angeles Street, Los Angeles, CA 90012 (about 35 miles west on the 60). Appointments at 844-545-5640. Chino Hills sits on the boundary; pick the calendar that's available first.

Federal — US Tax Court trial city

Los Angeles is the nearest of five California trial cities. Trial calendars run at the Edward R. Roybal Federal Building, 255 E Temple Street, Los Angeles. Tax Court petitions on behalf of Chino Hills clients designate Los Angeles as the place of trial under Tax Court Rule 140.

Federal — US District Court

Chino Hills sits on the CDCA division boundary. Eastern Division (Riverside): George E. Brown, Jr. Federal Building, 3470 Twelfth Street, Riverside, CA 92501. Western Division (Los Angeles): 255 E Temple Street, Los Angeles. Refund actions and Tax Court appeals route to one of these depending on the controlling division for the specific 91709 address.

State — FTB Field Office

FTB San Bernardino Field Office, 464 W 4th Street, San Bernardino, CA 92401 (about 26 miles east). Residency audits under R&TC §17014, NPA protests under §19031, FTB Settlement Bureau review under §19443. Most resolution work runs via MyFTB and FTB Form 3520 PoA without an in-person visit. Customer service 800-852-5711.

State — CDTFA Field Office (Diamond Bar)

Effective March 18, 2024, the new CDTFA Diamond Bar district office at 21680 Gateway Center Drive, Suite 200, Diamond Bar, CA 91765 succeeded the closed West Covina office. All Chino Hills sales-tax audits and petitions for redetermination route here. About 10 miles northwest of Chino Hills on the 60/57. Customer service 1-800-400-7115.

State — Office of Tax Appeals

OTA Sacramento HQ with Los Angeles and Fresno hearing rooms. R&TC §19324 petitions filed within 30 days of FTB Notice of Action. We appear at the Los Angeles hearing room at 355 S Grand Avenue for Chino Hills clients.

California Court of Appeal

Fourth District, Division Two (Riverside and San Bernardino Counties). Chino Hills tax-refund appeals from San Bernardino County Superior Court route here. 3389 Twelfth Street, Riverside, CA 92501.

County — San Bernardino County Treasurer-Tax Collector

268 W Hospitality Lane, First Floor, San Bernardino, CA 92415. Mon-Fri 8:00am-5:00pm. Property tax payment, redemption, and tax-defaulted property questions for Chino Hills parcels (including Vellano, Sleepy Hollow Estates, Las Lomas, Avila Hills, and Carbon Canyon parcels).

County — San Bernardino County Assessor

172 W Third Street, Fifth Floor, San Bernardino, CA 92415. Phone 909-387-8307. Prop 13 base-year value, Prop 19 parent-child claims, supplemental assessments, decline-in-value (Prop 8) review for Vellano, Sleepy Hollow Estates, Las Lomas, Avila Hills, Carbon Canyon, and the rest of the 91709 ZIP.

County — Assessment Appeals Board

San Bernardino County Clerk of the Board of Supervisors, 385 N Arrowhead Avenue, 2nd Floor, San Bernardino, CA 92415-0130. Phone (909) 387-4413. Regular roll filing July 2-November 30. Supplemental within 60 days of mailing.

City of Chino Hills — Civic Center

14000 City Center Drive, Chino Hills, CA 91709. Phone (909) 364-2600. Business license under Chino Hills Municipal Code, Mello-Roos CFD administration for Vellano, Sleepy Hollow Estates, Las Lomas, Avila Hills, and related CFDs. Chino Hills combined sales tax 7.75%.

EDD — Employment Development Department

EDD Tax Branch, statewide. DE 88 PoA. Petitions of DE 1870 worker-classification determinations heard in Los Angeles. We represent Chino Hills employers on payroll-tax disputes, AB 5 worker-classification audits, and §6672 trust-fund recovery exposure.

Talk to a California Tax Attorney About Your Chino Hills Matter

Free, confidential consultation. We review your IRS, FTB, CDTFA, EDD, AAB, FBAR, or estate-tax notice on the call and tell you what your options actually are.

Call (800) 883-8301 Schedule a Consultation

Chino Hills Tax Attorney FAQs

I have NRE, NRO, and FCNR accounts in India at ICICI, HDFC, SBI, or Axis Bank. As a Chino Hills resident, what do I actually have to file?

If the aggregate value of all your foreign financial accounts crossed $10,000 at any point in the calendar year, you file FinCEN Form 114 (the FBAR) electronically with the Treasury by April 15, with an automatic extension to October 15. That covers NRE rupee deposits, NRO accounts holding Indian-source income, FCNR foreign-currency time deposits, demat accounts at ICICI Direct, HDFC Securities, or Zerodha, and any mutual-fund SIPs at HDFC, ICICI Prudential, SBI Mutual Fund, or Axis Mutual Fund. Separate from FBAR, Form 8938 (Statement of Specified Foreign Financial Assets) attaches to your Form 1040 if your aggregate hits $50,000 on the last day of the year or $75,000 at any point (married-filing-jointly thresholds are double). The Indian mutual-fund SIPs almost always trigger Form 8621 PFIC reporting under IRC §1296 or §1297 — by default a punitive excess-distribution regime under §1291, but a mark-to-market election under §1296 levels the federal tax bite. Interest from NRE accounts is tax-free in India but fully taxable on Form 1040 Schedule B, and the Form 1116 foreign tax credit for any Indian TDS withheld follows. We handle the unified federal package for Chino Hills households across the 91709 ZIP.

Our family has accounts at Bank of China, ICBC, China Construction Bank, or China Merchants Bank. Same Chino Hills resident — what's different from the Indian compliance track?

The FBAR and Form 8938 mechanics are identical — the trigger thresholds, the filing methods, and the penalty exposure are the same. What changes is the underlying account type and the local-tax interaction. Chinese banks more often hold structured wealth-management products (lǐcái chǎnpǐn) that look like deposits in everyday use but qualify as PFICs under IRC §1297 because they hold pooled passive securities. Insurance-linked savings products from PICC, Ping An, or China Life also test as PFICs. Property in China gets complicated because the underlying ownership is a 70-year leasehold, not freehold, and the U.S. treatment as real property holds on Form 8938 only if the lease is held directly in the taxpayer's name (a lease through a relative or a household-registration nominee doesn't reach Form 8938 the same way). Renminbi exchange-rate movement creates §988 currency-gain timing on every NRO-equivalent redemption. We handle the unified package and the §1296 mark-to-market election year over year for Chino Hills Chinese-American households.

We bank in Korea at KEB Hana, Woori, Shinhan, KB Kookmin, or Bank of Hope (the LA-based Korean-American bank). What's the FBAR analysis for a Chino Hills Korean-American family?

FBAR and Form 8938 thresholds match — the foreign-account reporting is the same regardless of country. Bank of Hope is a U.S. bank (NASDAQ: HOPE), so a Bank of Hope account in Diamond Bar, Chino Hills, or Buena Park is not foreign for FBAR purposes. KEB Hana, Woori, Shinhan, KB Kookmin, and IBK are Korean banks — those go on FBAR. Korean ISA (Individual Savings Account) and Korean tax-deferred savings under the National Pension Service interact with the U.S.–Korea income tax treaty signed in 1979 and updated since. The treaty's saving clause means U.S. citizens and green-card holders are still taxed by the IRS on worldwide income, but the treaty's foreign-tax-credit and tie-breaker residency articles still apply. We see Korean mutual funds and equity-linked savings plans test as PFICs under §1297 regularly. The cleanest pattern is a §1296 mark-to-market election for every PFIC line, an FBAR for every foreign account, and a Form 8938 statement consolidating everything.

I bought a home in Vellano, Sleepy Hollow Estates, Las Lomas, or Avila Hills — Chino Hills' newer master-planned developments. My property tax bill is way over 1% of assessed value. Why?

Proposition 13 caps the ad valorem rate at 1% of factored base-year value with a 2% annual inflation cap. The excess on your bill is split between voter-approved general-obligation bonds (Chino Valley Unified School District, Chino Valley Independent Fire District, Chino Hills community college, Inland Empire Utilities Agency) and Community Facilities District (CFD) special taxes under California Streets & Highways Code §53311 (the Mello-Roos Community Facilities Act of 1982). Vellano, Sleepy Hollow Estates, Las Lomas, Avila Hills, and parts of Carbon Canyon are inside one or more CFDs that financed roads, sewer, water, parks, and school facilities for the development. CFD special taxes can add $3,000 to $9,000 a year per parcel and run 25 to 40 years from formation. They survive Prop 13 because they are not ad valorem. The federal §164(a) state and local property tax deduction (limited to $10,000 under §164(b)(6) through 2025) only covers the ad valorem portion under Treas. Reg. §1.164-4 — the CFD special-tax line is generally not deductible because it funds local benefits to identifiable parcels rather than general government, per IRS Notice 2018-54 and the long-standing Treas. Reg. §1.164-4(b)(1)(ii) special-assessment rule. We unpack the property tax bill, identify the deductible vs non-deductible split, and (where the math works) advise on CFD prepayment release at the City of Chino Hills CFD administrator.

My parents passed and left me their Vellano or Carbon Canyon home in Chino Hills. The San Bernardino County Assessor sent a supplemental notice that wiped out the Prop 13 base-year value. What can I do?

Proposition 19, effective February 16, 2021, replaced the older Proposition 58 parent-child exclusion. The exclusion now requires that the child make the inherited property their primary residence within one year of the transfer date AND file the Homeowners' Exemption (Form BOE-266) AND, if the property's fair market value exceeds the parent's factored base-year value by more than $1 million (indexed annually), accept a partial step-up on the excess. A Vellano or Carbon Canyon home with a $400,000 base-year value and a $2.4 million fair market value at the parent's death will reassess on the $1 million excess above the $1.4 million ceiling. If you didn't move in within twelve months, or the home was your parents' vacation property rather than their principal residence, the property reassesses to full fair market value at the date of death (the change-in-ownership date). You have 60 days from the mailing date of the Notice of Supplemental Assessment to file an Application for Changed Assessment with the San Bernardino County Clerk of the Board at 385 N Arrowhead Avenue, 2nd Floor. We pair the AAB application with a §1014 stepped-up basis analysis so the income-tax basis on a future sale is correct, and we look at §6166 estate-tax installment elections where the Chino Hills estate qualifies under the closely-held-business and farm rules.

I work in Diamond Bar or downtown LA but live in Chino Hills off the 71/57/91 interchange. Am I a California resident? What if I take a job in Las Vegas, Phoenix, or Austin and keep my Chino Hills home?

The 71/57/91 commute is the Chino Hills norm, and California residency for state income tax follows R&TC §17041 (residents taxed on worldwide income) and §17951 (nonresidents taxed only on California-source income). If you live in Chino Hills full-time and commute to Diamond Bar, LA, San Bernardino, Riverside, or Orange County, you're a California resident and California taxes all your wages regardless of where your employer is. Where you commute to changes how the wages get sourced for any local-tax overlay (there isn't one for those counties) and how a Form W-2 with a Nevada or Texas employer-state designation gets reconciled. The departing-resident question — moving to Las Vegas, Henderson, Phoenix, Scottsdale, Austin, or Reno while keeping a Chino Hills home — runs through R&TC §17014 and §17015 plus the OTA's Appeal of Stephen Bragg (2003-SBE-002), Appeal of Bindley (2018), and the closer-connection nine-factor test. Keeping the Chino Hills home with utilities in your name, vehicles registered in California, kids in Chino Valley Unified, and California medical and accounting relationships is a strong Bragg pointer back to California even if you spend the majority of the year out of state. We've handled the Chino Hills / Las Vegas pattern repeatedly — the honest assessment upfront beats an FTB Notice of Proposed Assessment three years later.

Where do my Chino Hills CDTFA sales-tax matters go? I heard the West Covina office closed.

CDTFA closed its West Covina district office and opened the new Diamond Bar district office at 21680 Gateway Center Drive, Suite 200, Diamond Bar, CA 91765, effective March 18, 2024. All Chino Hills retail, restaurant, and warehouse sales-tax audit work routes through the Diamond Bar office now. The Riverside district office at 3737 Main Street is the secondary option when Diamond Bar's calendar conflicts. Toll-free customer service stays at 1-800-400-7115. We file CDTFA Form 392 power of attorney and step in front of the Diamond Bar assigned auditor before a Notice of Determination becomes final. Common Chino Hills CDTFA pickups: restaurant POS reconciliation for Crossroads at Chino Hills and Shoppes at Chino Hills tenants, online-retail nexus and Wayfair §6203 use-tax reporting, and out-of-state warehouse equipment delivered to Chino Hills with no use tax remitted. Petitions for redetermination run on a 30-day clock from the Notice of Determination date.

Our Chino Hills LDS (Latter-day Saints) congregation collects tithing. The IRS audited my Schedule A and disallowed part of the deduction. What's the substantiation rule?

IRC §170(f)(8) requires a contemporaneous written acknowledgment from the donee organization for any single charitable contribution of $250 or more. The acknowledgment must contain the amount of any cash contribution, a description (but not the value) of any non-cash contribution, and a statement of whether any goods or services were provided in exchange (and if so, a good-faith estimate of the value). The acknowledgment must be obtained on or before the earlier of the filing date of the return or the due date including extensions. The Church of Jesus Christ of Latter-day Saints sends an annual donor statement around year-end that meets the §170(f)(8) standard. The audit issues we see are usually (1) missing the contemporaneous timing — the donor didn't request the statement until after the audit started, and §170(f)(8) requires it before filing, and (2) cash contributions of $250-plus dropped into the sacrament collection without a follow-up record. Cash contributions under $250 still need a bank record or a written record from the donee under §170(f)(17). Non-cash contributions over $500 need Form 8283; over $5,000 needs a qualified appraisal. We handle the audit reconsideration, build the contemporaneous record where the bishop's office can document the year's contributions, and either close the audit or move to Appeals.

I'm a Chino Hills resident with a parent serving as a full-time minister or church-employed missionary. Can the §107 housing allowance still work?

IRC §107 excludes from gross income a minister of the gospel's housing allowance — either the rental value of a parsonage furnished as part of compensation or a designated cash housing allowance, capped at the lesser of (1) the amount designated by the employing church in advance, (2) the actual housing expenses, or (3) the fair rental value of the home including furnishings and utilities. The §107 exclusion was challenged in Gaylor v. Mnuchin (7th Cir. 2019) and survived. It applies to ordained, licensed, or commissioned ministers performing services in the exercise of their ministry — the Treasury Regulations and revenue rulings define this fact-specifically. Self-employment tax under SECA (IRC §1402(a)(8)) still applies to ministers on the §107 housing allowance unless an §1402(e) opt-out is filed, which is itself irrevocable and requires a conscientious-religious-objection statement. We see Chino Hills LDS, Korean-American Presbyterian, Indian-American Christian, and Catholic Diocese of San Bernardino clergy households running this analysis. The §107 exclusion does not extend to non-clergy church employees — the church secretary, accountant, or facility manager who isn't ordained doesn't get §107 treatment, and most IRS audit pickups in this area target staff misclassified as clergy.

I have a Carbon Canyon equestrian property in Chino Hills with significant acreage. Can a §170(h) conservation easement reduce my federal tax?

IRC §170(h) allows a federal income tax deduction for the donation of a qualified real-property interest to a qualified organization exclusively for conservation purposes — outdoor recreation or education, protection of a relatively natural habitat, preservation of open space (including farmland and forest land), or preservation of an historically important land area. The donation has to be (1) a restriction granted in perpetuity under §170(h)(2)(C), (2) to a §170(h)(3) qualified holder (a §170(c) charity or a governmental unit), and (3) exclusively for one of the conservation purposes listed. The deduction is the fair market value of the easement (the before-and-after method under Treas. Reg. §1.170A-14(h)(3)). Carbon Canyon equestrian acreage and the parcels adjacent to Chino Hills State Park and Carbon Canyon Regional Park are exactly the kind of open-space and natural-habitat parcels §170(h) was written for. The IRS has heavily audited syndicated conservation easements where promoters inflate appraised values to generate four-to-one or five-to-one deduction-to-investment ratios — those are Listed Transactions under Notice 2017-10 and IR-2020-130 with §6707A reporting penalties and §6694 preparer exposure. A non-syndicated, single-owner Carbon Canyon easement to the Wildlife Land Trust or the Hills For Everyone land trust is a different animal entirely. We handle the qualified appraisal coordination, Form 8283 Section B reporting, and audit defense if the easement valuation gets picked up.

My Chino Hills estate is worth somewhere between $20 million and $40 million — a mix of a Vellano home, a Carbon Canyon ranch, a closely-held business, and an investment portfolio. What does estate-tax planning look like?

The federal estate-tax exemption is $13.99 million per person for 2025 (indexed annually under IRC §2010(c)) and scheduled to revert to roughly $7 million per person at the start of 2026 unless Congress acts. Married couples with proper portability under §2010(c)(5) can shield up to $27.98 million federally. California has no state estate tax. The planning levers for a $20-40 million Chino Hills estate: (1) annual exclusion gifting under §2503(b) at $19,000 per donee for 2025, (2) §2503(c) trusts for minors, (3) GRATs under §2702 to push appreciation outside the estate, (4) intentionally defective grantor trusts (IDGTs) with installment sales, (5) family limited partnerships with valuation discounts for lack of control and lack of marketability (subject to §2036 retained-interest scrutiny), (6) §6166 14-year deferral of estate tax attributable to a closely-held business interest exceeding 35% of the adjusted gross estate, paying interest-only for years 1-5 at a 2% rate on the first $1 million (indexed) of deferred tax, (7) §1014 stepped-up basis planning so heirs aren't sitting on the original basis when they sell, and (8) §170(h) conservation easements on Carbon Canyon ranch acreage. We coordinate with the family's wealth-management and trust-administration counsel — we cover the federal estate and gift-tax audit defense plus the §6166 election and the appraisal-defense side.

I'm a Chino Unified or Chino Valley Unified School District teacher. How do CalSTRS, §403(b), and §457(b) interact?

Chino Valley Unified School District teachers are members of the California State Teachers' Retirement System (CalSTRS), a defined-benefit plan funded by employee contributions, employer contributions, and state contributions. Member contributions are mandatory and pre-tax for federal purposes (after-tax for California, which doesn't conform to the federal exclusion fully — the FTB tracks a different basis). The CalSTRS Defined Benefit Supplement and Cash Balance Benefit Program add on top. Most districts offer a §403(b) plan administered through a vendor list (Voya, AIG, Equitable, TIAA, Vanguard), and a §457(b) plan administered through CalPERS Supplemental Income. The federal contribution limits are independent across §403(b) and §457(b) — a teacher under 50 can defer up to $23,500 to each plan in 2025, plus catch-up contributions over 50 ($7,500) and the special §457(b) three-year-final catch-up. CalSTRS members are subject to Windfall Elimination Provision (WEP) and Government Pension Offset (GPO) reductions on Social Security if they have a separate Social Security work history — the Social Security Fairness Act signed January 2025 repealed WEP and GPO going forward but the implementation is rolling and back-payment timing matters. We handle the federal and CA tax-side on rollover, the §72(t) early-withdrawal analysis, and the CalSTRS service-credit purchase calculations.

I run a small Chino Hills business that pays officer compensation. The IRS picked up a Reasonable Compensation audit. How does this work?

S-corporation shareholder-employees owe themselves reasonable compensation on a Form W-2 before any K-1 pass-through under Rev. Rul. 59-221 and the IRS's S-corp employment-tax campaign (formerly the Officer Compensation Issue Practice Group). The IRS looks at comparable wage data (Bureau of Labor Statistics OEWS for the SOC code matching the actual work performed), the role you play in the business, hours worked, the business's profitability, and what an arm's-length employee would earn for the same function. If a Chino Hills S-corp earned $400,000 in net income and the shareholder paid himself a $50,000 W-2 while taking $350,000 as a K-1 distribution, the IRS will reclassify a portion of the K-1 as wages, assess FICA at 15.3% combined (the §3101 employee and §3111 employer shares), tack on §6651(f) fraudulent-failure-to-file penalties or §6662(b)(2) substantial-understatement penalties, and may extend the assessment statute under §6501(e) for substantial omissions. The §199A Qualified Business Income deduction at 20% of QBI is itself limited under §199A(b)(2)(B) to 50% of W-2 wages or 25% of W-2 wages plus 2.5% of unadjusted basis of qualified property at higher income — so paying a low W-2 to avoid FICA actually shrinks the §199A deduction. We pull comparable wage data, document the hours and the actual role, and either negotiate a partial reclassification or amend the prior-year returns to a defensible W-2 level.

I'm a Chino Hills resident with stock options at an LA-area or OC-area tech employer. What do I have to watch for at exercise and sale?

Three option types dominate: Non-qualified Stock Options (NSOs), Incentive Stock Options (ISOs) under IRC §422, and Restricted Stock Units (RSUs). NSO exercise creates ordinary W-2 wages on the spread between fair market value and strike, withheld by the employer. ISO exercise creates no regular-tax income but a positive adjustment for Alternative Minimum Tax under §56(b)(3) — the AMT trap that wrecked Chino Hills and broader IE engineers and managers in the 1999-2001 dot-com era and again in 2021-2022. The §53 minimum-tax credit recovers AMT paid in later years but only against regular tax in excess of tentative minimum tax. RSU vesting creates ordinary W-2 wages on the full fair market value of vested shares — the §83(b) election doesn't apply to RSUs (unlike restricted stock under §83(a)). Sale of ISO shares within 12 months of exercise or 24 months of grant is a disqualifying disposition under §421(b), converting the ISO bargain element from §1202 long-term capital gain back to ordinary income (and away from AMT preference). Section 1202 Qualified Small Business Stock can exclude up to $10 million of gain on a sale of qualifying C-corp stock held over five years at acquisition under five-year original-issue rules. California fully conforms to RSU and NSO ordinary treatment, has its own AMT under R&TC §17062 that runs differently from federal AMT, and does not conform to §1202 QSBS exclusion at all. We model the federal and California tax across the option lifecycle for Chino Hills clients.

I have foreign rental income from a property in India, China, or Korea, and I'm a Chino Hills resident. What do I report?

Foreign rental income reports on Schedule E (Form 1040) at full gross rent in U.S. dollars (translated at the spot rate on receipt, or a weighted-average annual rate for steady-state rentals under Rev. Rul. 90-79), with allowed deductions for real and personal property taxes paid to the foreign jurisdiction, mortgage interest on the foreign mortgage (subject to the $750,000 acquisition-debt limit under §163(h)(3) and the qualifying-residence rule), insurance, maintenance, property management fees, and depreciation. Foreign residential rental property depreciates over 30 years under §168(g)(1)(A) (TCJA changed this from 40 years for property placed in service after 2017), longer than the 27.5-year U.S. domestic schedule. Local rental tax paid in India under the Income Tax Act, in China under the Land Appreciation Tax or rental withholding regime, or in Korea under the consolidated real-estate holding tax (Jonghap Budongsan-se) generates a foreign tax credit on Form 1116 (or a deduction on Schedule A, but the credit is almost always better). FBAR applies to any rental escrow or property-management account holding more than $10,000 in aggregate with other foreign accounts. Form 8938 applies on top at the higher thresholds. We handle the unified Schedule E, Form 1116, FBAR, and Form 8938 package for Chino Hills clients with India, China, Korea, Philippines, or Mexico real-estate holdings.

My Chino Hills business uses Mello-Roos CFD financing on a commercial parcel. Can I still deduct the special tax federally?

The §164 SALT cap of $10,000 (under §164(b)(6) through 2025) only applies to individual taxpayers, not to businesses. A trade-or-business taxpayer deducts state and local taxes that are ordinary and necessary business expenses under §162 without the SALT cap — but the §164 special-assessment rule still applies. Treas. Reg. §1.164-4(b)(1)(ii) treats assessments for local benefits (specifically Mello-Roos CFD financing of roads, sewers, water, sidewalks, drainage, and similar capital improvements that benefit the assessed property) as capital expenditures rather than current deductions. The capital portion is added to basis under §263A and depreciated as part of the structure or the underlying land improvement, not deducted in the year paid. Some CFD special taxes fund ongoing maintenance and operations (a smaller share) — that operational portion is currently deductible. The City of Chino Hills CFD administrator can break out the capital-vs-operations split on the annual special-tax bill. For a commercial-parcel owner in Vellano Country Club, Sleepy Hollow, Carbon Canyon, or the Chino Hills business-corridor CFDs, we analyze the special-tax breakdown, capitalize the capital portion to basis, and currently deduct the operations portion.

Written by

Parham Khorsandi, Esq.

Managing Attorney, Victory Tax Lawyers, LLP

State Bar of California #266658

Verify on calbar.ca.gov

Reviewed by

Amir Boroumand, Esq.

Managing Attorney, Victory Tax Lawyers, LLP

State Bar of California #269570

Verify on calbar.ca.gov

Last Reviewed: . Pages on the Victory Tax Lawyers site are dual-attorney reviewed; the reviewing attorney signs off on accuracy of legal citations and entity information before publication.

Disclaimer

This page is attorney advertising under California Rules of Professional Conduct Rule 7.1 and Rule 7.2. No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers. The information on this page is general information for Chino Hills, California residents and is not legal advice for any specific matter. Reading this page or contacting the firm does not create an attorney-client relationship; that relationship is formed only by a signed engagement agreement. Past results referenced (including the settlement-range table above and the firm's cumulative $100M+ in relief figure) are not a guarantee, warranty, or prediction of similar results in your matter. Outcomes depend on the taxpayer's specific facts, available equity in assets, allowable expenses under IRS Collection Financial Standards, and applicable federal and California statutes. Victory Tax Lawyers, LLP is admitted to practice in the State of California; both Managing Attorneys are members of the State Bar of California. We are the responsible counsel for our Chino Hills clients in California state and federal forums — this page does not refer state-court matters out to other firms.

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