Florida v. California: Florida’s Supreme Court Attack on California’s Single-Sales-Factor “Special Rule”

NEWS & INSIGHTS Florida v. California: Florida’s Supreme Court Attack on California’s Single-Sales-Factor “Special Rule” Florida has filed an original-jurisdiction case in the U.S. Supreme Court, Florida v. California, attacking California’s “Special Rule” in Cal. Code Regs., tit. 18, § 25137(c)(1)(A). The complaint argues that excluding substantial occasional sales from California’s single-sales-factor apportionment formula leads […]

1-Factor vs. 3-Factor Apportionment

NEWS & INSIGHTS 1 Factor vs. 3 Factor Corporate Income Tax Apportionment When Apportionment Goes Too Far: Challenging Single Sales Factor and Market-Based Sourcing Distortion As states aggressively adopt single sales factor (SSF) apportionment and market-based sourcing (MBS) rules, businesses are increasingly subject to state tax assessments that appear disconnected from economic reality. In a […]