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Yes, if you are physically working even one day in California in a given year, the Franchise Tax Board expects you to file a non-resident tax return. (How enforceable this is will depend on your other ties to the state and your personal risk tolerance.)

At one point, California and New York were unique in this, but I believe the practice has spread to other states, especially as a result of remote work becoming more widespread.

The relevant case (from 1989) is https://caselaw.findlaw.com/court/ca-court-of-appeal/1772838....

Edit to add: as someone who moved out of California 10 years ago, I've been advised by a professional to basically continue filing a non-resident return forever. If I file a return that says 0 days in state and $0 owed, the FTB has a statutory time limit to contest that assertion. If I don't file anything, they claim they have an indefinite lookback period.




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