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Winds of Change in California in the Apportionment of Income of Banks and Bank Affiliates  


Author:  Roy E.  Crawford.; Roburt J.  Waldow.


Source: Volume 25, Number 04, March/April 2012 , pp.48-56(9)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

A series of recent amendments to the California Revenue and Taxation Code and the income apportionment regulations brings changes in the rules for apportionment of income of banks and bank affiliates included in a California combined report.

Keywords: California apportionment rules; destination or market sourcing of receipts from services and intangibles; single sales factor election; 18 Cal. Code Regs. Sec. 25137-4.2; cost of performance rules

Affiliations:  1: McDermott Will & Emery; 2: Jones Day.

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