Sales Factor

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Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Tax Law Alert: Sales Factor Excludes Amounts Received from the Sale of Goodwill

In a case argued by Stoel Rives, the Oregon Supreme Court upheld the judgment of the Oregon Tax Court in favor of Tektronix, Inc. The Supreme Court ruled that, for purposes of apportioning income, the sales factor excluded...more

California’s Proposition 39: Not-so-Mandatory Single Sales Factor

On November 6, California voters passed Proposition 39, which changes the state’s default apportionment to a single sales factor method. Additionally, Proposition 39 adopted a mandatory market-sourcing method for sourcing...more

California Tax Refund Opportunity Based on Gillette

Taxpayers should review their apportionment methodology for prior taxable years to determine whether they should file refund claims based on the Multistate Tax Compact's evenly weighted three-factor apportionment formula....more

Gillette Reinstated. If Compact is Elected, LCUP Penalty Shouldn't Apply

The First Appellate District of the California Court of Appeal has once again held that California taxpayers may avail themselves of the Multistate Tax Compact (the Compact) election, which allows for taxpayers to file...more

A Close Shave: California Court of Appeal Rules on Multistate Compact Election

On October 2, 2012, the California Court of Appeal issued an opinion on rehearing in The Gillette Company et al. v. Franchise Tax Board, reversing in full the trial court’s decision in favor of the Franchise Tax Board (FTB)....more

CA’s 20% LCUP Penalty Shouldn’t Apply to Compact Elections Under Gillette

Friday, Reed Smith partner and former FTB Chief Counsel Brian Toman submitted a written request for consideration at the FTB's meeting yesterday for the FTB to interpret the 20 percent Large Corporate Understatement Penalty...more

Gillette Ruling Could Impact Alabama and Other MTC Member States

On July 24, 2012, the California Court of Appeal reversed the trial court decision and granted the taxpayers’ requested refund claims that utilized an equally weighted three-factor apportionment formula. This despite the fact...more

Gillette Wins. You Win. Taxpayers Should Hurry to File California Refund Claims Before the Fall Deadline

Executive summary and action item Today, a California Court of Appeal held that taxpayers have the option of electing to single-weight (as opposed to double-weight) their sales factor to compute their California...more

Gillette wins California Multistate Compact Case in Court of Appeal

In 1966, the California Legislature adopted the Uniform Division of Income for Tax Purposes Act (“UDITPA”), a model law which had been promulgated in 1957 by the National Conference of Commissioners on Uniform State Law....more

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