Given California’s continuing budget woes, it comes as no surprise that certain tax provisions in California’s recent budget agreements have come under fire as corporate handouts that will cost the state billions in lost revenue over the next ten years and beyond.[1] While the pros and cons of elective single-sales-factor apportionment[2] and the sharing of tax credits among members of a combined reporting group[3] are currently under debate, one provision has provoked little controversy thus far. The California Legislature in February 2009 adopted a new definition of “gross receipts” for California sales factor purposes.[4]