Cal. Code Regs. tit. 18, § 25133
(3) If the employee's services are performed both within and without this state, the employee's compensation will be attributed to this state:
(C) if the base of operations or the place from which the service is directed or controlled is not in any state in which some part of the service is performed but the employee's residence is in this state.
The term “base of operations” is the place of more or less permanent nature from which the employee starts his work and to which he customarily returns in order to receive instructions from the taxpayer or communications from his customers or other persons or to replenish stock or other materials, repair equipment, or perform any other functions necessary to the exercise of his trade or profession at some other point or points. The term “place from which the service is directed or controlled” refers to the place from which the power to direct or control is exercised by the taxpayer.
Compensation is paid in this state if any one of the following tests, applied consecutively, are met: