News & Analysis as of

Apportionment

Blank Rome LLP

Sibling Rivalry: Florida v. California

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While most of us with a brother or a sister are used to them tattling to the parents over some perceived slight (real or imagined), it is rare for such squabbles to play out in court. Yet that is exactly what’s happening in...more

Baker Botts L.L.P.

California 2026 Billionaire Tax Act

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On October 22, 2025, a ballot initiative titled the “2026 Billionaire Tax Act” was filed with the California Attorney General. An amendment to the initiative was filed on November 26, 2025....more

Eversheds Sutherland (US) LLP

Eversheds Sutherland SALT Scoreboard - Quarter 3, 2025

This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be the significant taxpayer wins and losses and analyzed those results. Our entire...more

Kilpatrick

5 Key Takeaways | Pomp v Goodman at the 32nd Annual Hartman SALT Forum

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The Professor Paul J. Hartman Memorial State and Local Tax (SALT) Forum, sponsored in conjunction with Vanderbilt University Law School, is a premier event that offers industry professionals, practitioners, and state revenue...more

Haug Partners LLP

$10 Million Jury Award Reduced to $1 by Delaware District Court following JMOL Motion in Rex v. Intuitive: Federal Circuit Affirms

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In Rex Medical, L.P., v. Intuitive Surgical, Inc. (“Rex”), the Federal Circuit affirmed the District Court’s reduction of a jury award from $10 million to $1. At trial, with no damages experts testifying, a jury awarded $10...more

Irwin IP LLP

Federal Circuit Affirms $1 Nominal Damages Where Failure to Apportion Renders Damages Expert’s Testimony Unreliable 

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Rex Medical, L.P. v. Intuitive Surgical, Inc., Case No. 24-1072 (Fed. Cir. Oct. 2, 2025) - The Federal Circuit’s opinion in Rex Medical, L.P. v. Intuitive Surgical, Inc. underscores the judiciary’s strict insistence on...more

White & Case LLP

Federal Circuit Says Where Expert Evidence is Insufficient, Patent Damages Can Be Nominal

White & Case LLP on

On October 2, 2025, in Rex Medical, LP v. Intuitive Surgical, Inc., Nos. 2024-1072, 2024-1125, the U.S. Court of Appeals for the Federal Circuit affirmed a district court's preclusion of Rex's patent damages expert from...more

McDermott Will & Schulte

Damages? Apportionment among licensed properties is essential, $10 million award reduced to $1

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The US Court of Appeals for the Federal Circuit affirmed a district court decision excluding a damages expert’s testimony and reducing a jury’s $10 million damages award to nominal damages. The Court found that the plaintiff...more

Husch Blackwell LLP

Minnesota Supreme Court Rules on Sourcing Pharmacy Benefit Management Services

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Like many states, Minnesota uses a market-based approach for calculation of the corporate franchise tax apportionment, by sourcing sales of services to the state where the services are “received.” A recent decision by the...more

BCLP

Tort Reform and Beyond: Key Georgia Legislation Impacting Civil Litigation Since 2022

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Since 2022, the Georgia General Assembly has passed several pieces of legislation providing significant impacts for civil litigation and litigants in the State’s courts. Together, the new laws indicate a legislative trend to...more

Kilpatrick

Four Key Takeaways from the Top SALT Cases Impacting the Technology Sector

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Kilpatrick’s Jordan Goodman recently spoke at the Council On State Taxation – 2025 SALT Technology Workshop in the San Francisco Bay Area about the “The Top SALT Taxes Impacting the Technology Sector”. This workshop covered...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Baker Botts L.L.P.

Patent Apportionment: Anything You Say in a License Agreement May Be Used Against You in a Court of Law - UPDATED May 2025

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On May 21, 2025, the Federal Circuit “reverse[d] the district court’s denial of Google’s motion and remand[ed] for a new trial on damages.” The decision resulted in an 8-2 vote, with Judges Reyna and Stark dissenting. The...more

Akerman LLP - SALT Insights

A “Source” of Consternation? The Taxation of Telecommunications Companies in Florida

Like many states, Florida’s corporate income tax regime has special rules applicable to telecommunications companies. The tricky part about taxing the telecommunications industry is how to source receipts earned from...more

Baker Botts L.L.P.

Patent Apportionment: Anything You Say in a License Agreement May Be Used Against You in a Court of Law

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Over the last several years, the Federal Circuit has increasingly scrutinized patent litigants’ reliance on “comparable licenses” as a means for calculating a reasonable royalty, including whether the license needs to be...more

A&O Shearman

Federal Circuit Clarifies Requirements To Establish Convoyed Sales In Patent Damages

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On March 24, 2025, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) issued an opinion affirming a district court’s judgement of infringement while vacating and remanding the district court’s damages...more

Akerman LLP - SALT Insights

It’s None of My Business! Arkansas Court Rules on Business v. Non-Business Income Distinction

Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more

Davis Wright Tremaine LLP

Nonresidents Beware: Oregon's and Washington's Fractional Formula and Apportionment Rules Apply to In-State Property

At $13.99 million for 2025, the federal estate tax exclusion is the largest it has ever been, but it will be reduced by half in 2026, which you can read more about in this advisory....more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

Pierce Atwood LLP

Maine Revenue Services Proposes Amended Rule to Adopt Look-Through Apportionment

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On December 6, 2024, Maine Revenue Service (MRS) published a proposed amendment to its apportionment regulation, Rule 801, which would effectively adopt look-through apportionment of certain service receipts, apparently...more

Axinn, Veltrop & Harkrider LLP

Apportionment of Trade Secret Damages: Will Phillips 66 Ask A Six Hundred Million Dollar Question?

In a trade secret misappropriation action, a complainant is required to prove the amount of its damages with reasonable certainty and that this amount has been caused by the misappropriation. Therefore, the trade secret...more

Pillsbury - SeeSalt Blog

California’s Market-Based Sourcing Amendments; Public Hearing Requests Due by Oct. 16

The California Franchise Tax Board (FTB) announced it has initiated the formal rulemaking process to amend Regulation Section 25136-2, which governs the sourcing of receipts from services and intangible property.  The...more

Kilpatrick

4 Key Takeaways - Is it Time to Start Apportioning Use Taxes?

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Kilpatrick’s David Hughes recently participated in a panel discussion at the 55th Annual Council on State Taxation (COST) Annual Meeting in St. Louis. The session, “Is it Time to Start Apportioning Use Taxes?,” explored...more

WilmerHale

The Broken Balance: How “Built-in Apportionment” and the Failure to Apply Daubert Have Distorted Patent Infringement Damages

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The United States patent system is designed to be a balance: in exchange for the inventor disclosing their invention to the public, pa-tentees are granted exclusive rights to that invention for a period of time. This ensures...more

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