California’s market-based sourcing rules

Published: 06 February 2017

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The California Franchise Tax Board (FTB) recently held  its first Interested Parties Meeting (IPM) for the next round of proposed amendments to its market-based sourcing rules under the California Code of Regulations (Section 25136-2 regulations).

Prior to the meeting a discussion draft was facilitated,  including examples (previously withdrawn) on how California State rules would apply in the context of asset management firms. We understand the consultation was held in response to FTB’s push to provide look-through rules in assigning receipts to investment managers. The FTB also seems open to accepting written comments ahead of future meetings with stakeholders.
For further information, please contact Paul Hale or Enrique Clemente.