Inclusion Of Business Income Dividends In The Recipient'S Sales Factor Form - California Franchise Tax Board Page 3

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Legal Ruling 2003-3
December 4, 2003
Page 3
HOLDING
Situation 1: Because A participates in the management and operations of B, it engages
in income-producing activity with respect to the dividend so that the dividend is includible
in A's sales factor.
Situation 2: Because C does not participate in the management and/or operations of S, it
does not engage in income-producing activity with respect to the dividend, and the
dividend is not includible in C's sales factor.
CONTACT INFORMATION
For further information regarding this ruling, please contact Carl Joseph at the Franchise
Tax Board, Legal Department, P.O. Box 1720, Rancho Cordova, CA 95741-1720.

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