JustinJ.
HepworthHe / Him / His

Partner
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Justin Hepworth

Overview

Justin Hepworth’s practice encompasses a broad range of state and local tax matters, from planning, compliance and transactional work to audit-related tax controversy and litigation. He regularly defends state and local tax audits and advises clients on the tax implications of restructurings, mergers, acquisitions, spinoffs and asset sales.

Justin’s experience includes assisting clients with:

  • California residency planning and residency audit defense
  • Income, sales and use, and local business license tax audit defense
  • Various multistate issues, including nexus, sales and use tax exemptions, sourcing and characterization, research and development credits, and unitary business matters
  • California property tax planning, including Proposition 13 change in ownership, real estate transfer tax and institutional exemptions

Justin is a member of the Tax Sections of the California, Texas and American Bar Associations. He is a frequent speaker on state tax matters at conferences throughout the country, including those sponsored by the American Bar Association, the State Bar of California Taxation Section and the Tax Executives Institute (TEI). He is also a member of the State and Local Tax Committee of the California Lawyers Association and the California representative for the United States Law Firm Group State and Local Tax Committee.

When he has time, Justin enjoys travel and attempting to hit a 1.68-inch white ball into a 4.25-inch hole.

Experience

Represented numerous California taxpayers in income tax residency audits and disputes, including sourcing of stock options and related petition for recovery of attorneys’ fees.

Represented a large information services company in a California franchise tax protest of the Franchise Tax Board’s disallowance of claimed research tax credit.

Represented numerous taxpayers in Los Angeles business license tax audits.

Represented a large company in a Texas franchise tax unitary business dispute.

Represented a large event services company in a California sales and use tax audit.

Represented a large information services company in appeal and litigation of an Illinois business/nonbusiness income issue.

Represented a large SaaS company on multistate issues regarding characterization and taxability of services for indirect tax purposes, including planning, voluntary disclosure, and audit defense.

Represented various California commercial solar developers and investors on a myriad of California tax issues, including sales and use tax and property tax exemptions.

Credentials
Education

J.D., Tulane University, 2010, magna cum laude, Order of the Coif, Managing Editor of the Tulane Law Review

B.S. University of Idaho, 2006

Admissions

California

Texas

Thought Leadership
  • Co-Author, “Tax Alert,” California Lawyer's Association's California Trusts and Estates Quarterly, Volume 31, Issue 3, 2025
  • Co-Author, “Tax Alert,” California Lawyer's Association's California Trusts and Estates Quarterly, Volume 31, Issue 2, 2025
  • Co-Author, “Tax Alert,” California Lawyer's Association's California Trusts and Estates Quarterly, Volume 31, Issue 1, 2025
  • Co-Author, “Tax Alert,” California Lawyer's Association's California Trusts and Estates Quarterly, Volume 30, Issue 4, 2024
  • Contrasting California and New York Current Trends in Income Taxation, TEI Silicon Valley Chapter State and Local Tax Day, April 19, 2018.
  • South Dakota v. Wayfair: What Are the Implications, However Decided?, TEI Silicon Valley Chapter State and Local Tax Day, April 19, 2018.
  • California’s Department of Tax and Fee Administration, Office of Tax Appeals, and Other State Administrative Updates, TEI Silicon Valley Chapter State and Local Tax Day, April 19, 2018.
  • Multistate All-Tax Update on Hot Topics, TEI Silicon Valley Chapter State and Local Tax Day, April 19, 2018.
  • Real Estate Transfer Taxes and Changes in Entity Ownership – Avoiding Pitfalls, American Bar Association, Tax Section, 2018 Midyear Meeting, February 9, 2018.
  • The Market Based Sourcing Rules: Flexibility is Good, Right?, California Tax Bar and California Tax Policy Conference, October 27, 2016.
  • State Tax M&A Considerations, TEI Orange County Chapter State and Local Tax Day, May 11, 2016.
  • Transactional Taxes, TEI Orange County Chapter State and Local Tax Day, May 11, 2016.
  • Recent Developments in SALT Litigation, TEI Orange County Chapter State and Local Tax Day, May 11, 2016.
  • Successes and Setbacks – Recent Developments in SALT Litigation, TEI Silicon Valley Chapter State and Local Tax Day, April 21, 2016.
  • Don’t Forget About Us – State Tax M&A Considerations, TEI Silicon Valley Chapter State and Local Tax Day, April 21, 2016.
  • Texas Tax Update: Key Developments in Margin, Sales and Property Taxes, Webcast, 2013.
  • Limiting and Challenging Nexus with Texas, Webcast, April 19, 2012.
  • Unclaimed Property Update, Webcast, February 9, 2012
  • What Nortel Really Means For Your Business in California, Webcast, October 6, 2011
  • Tax-Saving Tips for the Texas Manufacturing Exemption, Journal of State Taxation (CCH), March-April 2011.
  • Texas Comptroller Amends Position on Amended Margin Tax Return Deductions, Corporate Business Taxation Monthly (CCH), December 2010.

Books

  • Cloud Computing Legal Deskbook, Chapter 7: Tax Issues in the Cloud, Thompson Reuters, 2015-2017 editions.