California regulation amendment provides market based sourcing guidance for receipts from marketable securities, dividends, goodwill, and interest

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September 2016

Overview

On September 15, 2016, the Office of Administrative Law approved the California Franchise Tax Board’s changes to its regulation dealing with sales other than sales of tangible personal property regarding the sourcing treatment of revenue from marketable securities, dividends, goodwill, and interest.

Taxpayers should be aware that the amendments are applicable for the 2015 tax year, which could impact tax filings that are due under extension this compliance season.

The absence of examples regarding asset management fees continue to leave questions unanswered regarding the sourcing treatment of such fees.

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Peter Michalowski

Peter Michalowski

State and Local Tax Leader, PwC US

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