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Proposed Addition to Regulation Section 25137(b)

(1)(C) Where tangible personal property owned or rented by the taxpayer is not physically located in any state, such as orbiting satellites, undersea transmission cables and the like, the property shall be excluded from the numerator and from the denominator of the property factor. To the extent such property is located in the jurisdiction of any state it shall be included in the property factor denominator and excluded from the property factor numerator. See Revenue and Taxation Code Section 25120(f) for definition of state.