Ruling Nº 2020-02 from the State of California, 2020

• Ruling Number: 2020-02
• Year: 2020
• Date: 23 December 2020
• Type of Document: Chief Counsel Ruling

STATE OF CALIFORNIA

FRANCHISE TAX BOARD

Legal Division MS A260

PO Box 1720

Rancho Cordova, CA 95741-1720

tel: 916.845.2578 fax: 916.843.0453

ftb.ca.gov

chair Betty T. Yee| member Antonio Vazquez| member Keely Bosler

12.23.2020

******* **** ********* **** ***

***** ******* **** *****

*** **** ****** ******

************* ** *****

Chief Counsel Ruling 2020 - 02

RE: Chief Counsel Ruling Request for **** ******** ******* *******; ********

***** ******* ***; ***** ** ******* ******* *******, ****; and *******

********* ****

Dear *** ***** ,

This letter is in response to your Chief Counsel Ruling ("CCR") request dated ******* **,

****. In the request, you ask for the Franchise Tax Board's ("FTB") guidance as to the

assignment of sales of tangible personal property for California franchise and income tax

purposes.

FACTS

**** ******** ******* ******* ("****"), headquartered in ***** ********, is in

the business of selling tangible personal property (interchangeable with "products"). As

relevant to this ruling, ****** affiliates include ******** ***** ******* ***, *****

** ******* ******* *******, ****, and ******* ********* **** (collectively, the

"**** ******** *****"), all of which are also in the business of selling tangible personal

property. **** and its affiliates file a combined report in California pursuant to Revenue

and Taxation Code section 25105, subdivision (a).

The **** ******** ***** sells its products to various purchasers, including ******

*******, **** ("******") outside of California and ****** *******, **** ("******

*******") in California. ******, headquartered in *****, is in the business of

wholesaling and distributing tangible personal property throughout the nation from various

distribution centers in several states, including California. ****** or its wholly-owned

affiliates (collectively, the "****** ******** *****") operate the centers. One such

affiliate is ****** *******, which operates from distribution centers in **********,

*******, and *******.

The **** ******** ***** will transport nearly all the products it sells to the ******

******** ***** via common carrier to the new ****** consolidation warehouse in