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California Taxation of Entities in Banking Groups: The Crucial Calculation of Financial Versus General  


Author:  James D. Goeller.


Source: Volume 19, Number 01, September/October 2005 , pp.21-26(6)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

California is a state that taxes corporations that engage in financial activities differently than other corporations. A recent case tax case, City of Los Angeles v. Furman Selz Capital Management, L.L.C., highlights several points that financial services taxpayers should consider in filing California Combined Reports. The classification of financial versus general (1) impacts whether the California in-lieu tax will apply and the apportionment rules to follow, and (2) can impact whether the group should double weight the sales factor in apportioning income to California and the ancillary taxes imposed by the State of California and its political subdivisions.

Keywords: 

Affiliations:  1: Perry-Smith LLP.

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