Fair apportionment is a constitutional requirement. According to Complete Auto Transit Inc. v. Brady, 430 U.S. 274 (1977), to be fairly apportioned, a state tax on corporate income must be limited to ...

Following its February 26, 2026 Proposed Statement of Decision, the California Superior Court issued a final Statement of ...

Why only seek an alternative formula when you can win under the normal formula? A corporate taxpayer won under a special-industry normal apportionment formula, and it won the right to use an ...

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This is the last of four posts that discuss the original legal force of the terms the Constitution employs to denote financial exactions. This series is based, for the most part, on my forthcoming ...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in ...

Applying the time-based apportionment formulas to determine capital gains can have absurd results and seriously prejudice taxpayers. The attempt at simplicity has resulted in a lack of equity in the ...

Technology is enabling businesses to perform tasks more efficiently and provide services to customers in ways they never thought possible. Yet these novel processes and products present considerable ...