Search for: "Swart Enterprises v. Franchise Tax Bd." Results 1 - 7 of 7
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17 Jan 2020, 12:57 pm by Robert P. Merten III and Mike Le
Since then, the following decisions, rulings, and other notices were issued but uncertainty still abounds: FTB Technical Advice Memorandum No. 200658 (citing Amman & Schmid and holding that while an out-of-state LLC member receiving California-sourced income was subject to state income tax, it was not doing business for California franchise tax purposes).29 FTB Legal Ruling 2014-01 (reversing course, the FTB describes Amman & Schmid as a narrow exception not… [read post]