California's sales factor apportionment rules

Exploring market-based sourcing

Among the many apportionment factor modifications contained in budget legislation, this article focuses on California's switch to market-based sourcing for sales that result from transactions other than the sale of tangible personal property.

California tax law changes

In February 2009, California enacted budget legislation containing significant California tax law changes. These changes include important modifications to the apportionment formula that California used to determine the California-source income of multistate corporate taxpayers for income and franchise tax purposes. Effective for tax years beginning on or after January 1, 2011, these apportionment factor modifications will impact the California corporate income tax liabilities of a large number of multistate companies doing business in California.


By Valerie Dickerson and Fred Thomas of Deloitte Tax LLP | Originally published in the California Tax Lawyer in Spring 2010
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