3 Things to Know About Florida v. California at High Court, Law360

Partner Will Gorrod was quoted in a Law360 article examining Florida’s unexpected bid to challenge California’s use of single-sales-factor apportionment and its occasional sales rule before the US Supreme Court.

Will noted that Florida’s challenge centers on its view that California’s occasional sales rule skews how income is apportioned, particularly when a taxpayer has a one-time, high-value transaction outside its normal line of business. Florida is contending that excluding such transactions from the denominator shifts an outsized share of income to California.

“If there was a significant sale and that’s excluded from the factor, then it’s their argument that this is significantly increasing the California tax because they are not diluting the factor by including those Florida sales in the denominator,” he said.

Read the full Law360 article >>