California Regulation §25136-2, Sales Other than Sales Of Tangible Personal Property - Part II: Intangible Property

The Bloomberg BNA Tax Management Weekly State Tax Report filters through current state developments and analyzes those critical to multistate tax planning.

California's version of market based sourcing for sales other than sales of tangible personal property, California Code of Regulations (CCR) § 25136-2, consists of two sets of cascading rules for determining the assignment of sales for taxpayers that elect single sales factor apportionment. The rules address assignment of sales for both services and intangible property. In this article, the second in a two part series, Mr. George Famalett and Mr. Rakhal Bhalla, of PricewaterhouseCoopers LLP, discuss the assignment of sales of intangible property, having covered sales of services in their prior installment.