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
The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more
Taxpayers should review their apportionment methodology for prior taxable years to determine whether they should file refund claims based on the Multistate Tax Compact's evenly weighted three-factor apportionment formula....more