CCH (cch.taxgroup.com) reports:
 The California Franchise Tax Board has issued a legal ruling clarifying the application of the real estate mortgage investment conduit (REMIC) excess inclusion rules for members of a California franchise tax unitary combined reporting group. The minimal amount of a California noneconomic residual interest (NERI) holder's excess income from a REMIC that is reported on the NERI holder's tax return must be determined on a post-apportioned basis if the NERI holder is included in a California combined report. Furthermore, the minimal excess income amount is not included in the NERI holder's gross income or taxable income for purposes of calculating the NERI holder's California net operating loss carryforward.
Legal Ruling 2009-01 , California Franchise Tax Board, January 26, 2009,
¶404-839
 Other References:
 Explanations at ¶10-365
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