Taxation

Ca. Tax Lawyer VOLUME 33, ISSUE 1, DECEMBER 2024

AN OVERVIEW OF THE HISTORY OF CALIFORNIA RESIDENCY

By Desiree Macedo1

This article focuses primarily on the evolution of the California residency statutes and regulations. While presumptions related to residency and non-residency exist in Revenue and Taxation Code (Rev. and Tax. Code) sections 17014, 17015, and 17016; as well as Cal. Code Regs., Title 18, sections 17014 and 17016, this paper will focus on the origins of what is now Rev. & Tax. Code section 17014.

WHY IS A RESIDENCY DETERMINATION IMPORTANT?

The policy behind California’s personal income taxation of residents is to ensure that individuals, who are physically present in the state enjoying the benefits and protections of its laws and government, contribute to its support, regardless of the source of their income.2

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