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Expert Analysis

Market-Based Sourcing: A Common (Sense) Approach

By Maria Eberle and Laura Grace Mezher (August 31, 2017, 12:55 PM EDT) -- Earlier this year, the California Franchise Tax Board (FTB) issued Chief Counsel Ruling 2017-01, which addresses the application of the state's market-based sourcing rules to non-marketing services under California Revenue and Taxation Code Section 25136 and California Code of Regulations Section 25136-2. The ruling concludes that receipts from non-marketing services should be sourced to California to the extent that a taxpayer's direct customers (and not its customer's customer) receive the benefit of the service in California....

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