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Calif. OTA Ruling May Limit Foreign Income State Can Reach, Law360


Partner Will Gorrod was quoted in a Law360 article about an opinion from California's Office of Tax Appeals allowing Microsoft to include all of its foreign dividends in the denominator of its California sales factor and what the decision could mean for other multinational corporations in similar circumstances.

Will noted that California, among other states, has been seeking to expand the income tax base of multinationals to include more foreign income, even as other policies have been enacted to prevent such an outcome.

"I think there's been this creep into more and more foreign income, and so I think it's important to note that this is some sort of limitation on that, for California purposes," Will said.

Read the full Law360 article >>