California throwback nexus decision for pre-2011 years

December 2012


The California Franchise Tax Board ("FTB") recently issued Technical Advice Memorandum ("TAM") 2012-01, which concludes that for tax years beginning before January 1, 2011, a California taxpayer must demonstrate physical presence (either directly or through agents or independent contractors) in the destination state in order to avoid the application of the throwback rule.

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