Category Archives: Multistate Tax Law

U.S. Supreme Court Denies Three-Factor Apportionment Review

The United States Supreme Court denied review of Gillette Co. v. California Franchise Tax Board, the California Supreme Court case holding that taxpayers may not use the Multistate Tax Compact’s three-factor apportionment method to apportion their income under the California Business Income Tax.  As is customary, the Court didn’t explain its reasons for denying review.  […]


Court of Appeals Rules No Three-Factor Apportionment, Texas Franchise Tax Is Not an Income Tax

The Texas Third Court of Appeals issued its opinion yesterday in Graphic Packaging Corp. v. Hegar, No. 03-14-00197-CV.   It ruled that taxpayers may not choose to use the Multistate Tax Compact’s three-factor apportionment method to apportion their taxable margin under the Texas franchise tax.  In doing so, the Third Court of Appeals held that the […]


Supreme Court rules in state tax case

The United States Supreme Court recently decided Direct Marketing Association v. Brohl, a state tax case. In it, the Supreme Court ruled that a challenge in federal court to Colorado’s so-called “Amazon law” could go forward, contrary to Colorado’s argument that the Tax Injunction Act barred the suit. In perhaps a more interesting development for […]


Michigan Supreme Court OKs Three-Factor Apportionment, Possible Texas Franchise Tax Implications

In its recent decision in IBM Corp. v. Department of Treasury, the Michigan Supreme Court ruled that taxpayers may apportion their tax base for the Michigan Business Tax using the three-factor apportionment method provided by the Multistate Tax Compact instead of the single-factor apportionment method the Michigan Business Tax statute provided.  The decision means that […]


Supreme Court to review three state tax cases

The United States Supreme Court has already announced that it will review three state tax cases in its upcoming term — Comptroller v. Wynne, Direct Marketing Association v. Brohl, and Alabama Department of Revenue v. CSX Transportation, Inc.  This is unusual as the Supreme Court rarely reviews state tax cases.  While none of these cases involve […]


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