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.
Click the 'X' in the top right corner to close this window.
Of further interest