California’s New Sales Location Rules Risk Sowing Tax Confusion

Sept. 30, 2025, 8:45 AM UTC

Tax professionals are closely watching how flexible a California agency will be in applying its long-awaited guidance on where consulting firms, asset managers, and other service-oriented businesses should assign the location of their sales for tax purposes.

The new rules from the Franchise Tax Board take effect Wednesday after nearly a decade of revision. They clarify how companies are supposed to source sales in California, specifically for intangible items like government contracts and asset management fees where determining the location of the benefit of the sale is difficult or impossible.

The location assigned to these sales matters, especially for multi-state ...

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