In the closely watched “Paula Trust” case, the California Court of Appeal, First Appellate District held that all of a trust’s California source income is subject to California income tax even though one of the trustees was a nonresident. Steuer v. Franchise Tax Board, No. A154691 (Cal. Ct. App. 1st Dist. June 29, 2020). The trust’s non-California source income would be apportionable. California imposes income tax on 100% of a trust’s income if all trustees…

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