A non-California corporation’s only connection with California was its passive minority interest in a limited liability company (LLC) that was doing business in California. The California Court of Appeal held that this limited connection was not sufficient to subject the out of state corporation to California’s Corporation Franchise Tax. All taxpayers that have filed and paid California corporation franchise tax based solely on the ownership of a passive membership interest in an LLC that is doing business in California should consider whether they may be able to submit a refund claim.  To read the full GT Alert, click here.