Apportionment Issues

Schadewald, Michael S.
November 2008
Journal of State Taxation;Nov/Dec2008, Vol. 27 Issue 1, p7
Academic Journal
The article reports on the argument concerning the amendment made by the California Franchise Tax Board (FTB) which focuses on eliminating treasury function receipts from sales factors in the apportionment of corporation franchise and income tax. It reveals that the amendment prohibits business enteprises from including interest and dividends of their intangible assets in the numerator and denominator of sales factor. Information on the rulings made by the California Supreme Court to the lawsuits of Microsoft Corp. and General Motors Corp. against the FTB concerning the inclusion of treasury function receipts is also provided.


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