@Opus 17 --
CA does treat W-2 employees differently than independent contractors with regard to income sourcing. The income of a W-2 employee is sourced where the work is actually (physically) performed. But due to a 2019 court decision (the Bindley decision), the income of an independent contractor (which is normally reported on a 1099-NEC) is sourced to “the location where the taxpayer’s customer has either directly or indirectly received value from delivery of that service."
https://ota.ca.gov/wp-content/uploads/sites/54/2019/08/18032402_Bindley_Decision_OTA_053019.pdf
Thus an independent contractor who provides services to a client located in California is taxed by California on the income from those services, even if the independent contractor is a non-resident of CA and did not physically perform those services within CA.
Note that this ruling applies only to the State of California.
**Answers are correct to the best of my ability but do not constitute tax or legal advice.
