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McDermott Will & Emery

California Legislatively Overturns Recent Office of Tax Appeals Taxpayer Win

McDermott Will & Emery on

The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more

Pillsbury - SeeSalt Blog

Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

Pillsbury - SeeSalt Blog on

In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator....more

McDermott Will & Emery

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

McDermott Will & Emery on

The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

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