GA S-Corp donig Business in California

Technical topics regarding tax preparation.
#1
Posts:
152
Joined:
20-May-2014 3:08pm
Location:
Canton, GA
When a foreign (Georgia) S-Corp conducts business in California, what service income should be used to apportion income to California?

Facts - the S-Corp was formed in GA but is registered to conduct business in CA. For the year in question, roughly 10% of the services were provided inside CA while 90% was outside CA. The sole shareholder/employee is a CA resident and performs all of the services. FWIW, the shareholder is not an officer. The officers reside in GA and manage a stock portfolio for the S-Corp as well as helping the shareholder during travels to other states/countries to provide services.

I think that only the services provided in CA should be used; however, I want to confirm this belief.

Thanks,
 

#2
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8292
Joined:
4-Mar-2018 9:03pm
Location:
The Office
Both CA and GA are market based sourcing states (as opposed to cost of performance).

You should source revenue based on where the client/customer received the benefit of the service.
 


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