California FTB Amends Corporate Income Tax Market-Based Sales Sourcing Rules for Intangible Property

The California Franchise Tax Board (FTB) adopted amendments to the market-based sourcing rules for apportioning sales from services and intangible property for corporate income tax purposes. The regulations update the existing guidelines under Revenue and Taxation Code § 25136, which pertains to the assignment of sales, excluding those of tangible personal property, for the purpose of apportioning business income. The regulations take effect Oct. 1. [Cal. Franchise Tax Bd., Reg. Section 25136-2, 09/05/25, Cal. Reg. Notice Reg.]