California Legal Brief

AI-Generated Practitioner Briefs of California Appellate Opinions

business taxation

1 opinion tagged “business taxation”

Garcia-Rojas et al. v. Franchise Tax Board 5/1/26 CA1/3

The Rule of Garcia-Rojas v. Franchise Tax Board is that a nonresident sole proprietor engaging in only one business activity cannot constitute a "unitary business" for purposes of California taxation under regulation 17951-4(c), under circumstances where the taxpayer operates a single-activity sole proprietorship receiving compensation from one entity, even when that entity's clients are located both within and outside California.