State and Local Tax Alert - December 2014

December 2014

On November 14, 2014, the Fresno County (California) Superior Court held that Swart Enterprises, Inc. ("Swart"), an Iowa corporation that had as its only connection to California a non-manager, 0.2% interest in Cypress Equipment Fund XII, LLC (the "Fund"), a manager-managed California limited liability company ("LLC") treated as a partnership for federal income tax purposes, was not subject to the $800 minimum franchise tax (the "Minimum Franchise Tax").