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California Suit Challenges Mandatory Single-Sales-Factor Apportionment

By Dakessian Law | September 16, 2021

TaxAnalysts – State Tax Notes (September 16, 2021): A lawsuit filed in California seeks to overturn the state’s mandatory single-sales-factor apportionment requirement, which it says was unlawfully passed.

In One Technologies LLC v. Franchise Tax Board, a Texas company argues that it’s owed a refund for the tax it paid to California for the 2017 tax year. The company’s complaint says the refund is due because the law requiring it to determine its tax liability via single-sales-factor apportionment, which eliminated the option of electing to use three-factor apportionment, wasn’t lawfully passed.


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