California Court of Appeal

Plaintiffs successfully claimed the Franchise Tax Board had incorrectly applied the Revenue and Taxation Code concerning dividends received from its foreign subsidiaries. Plaintiff's claim that California's "water-s-edge" method of apportioning the combined income of a unitary business group for tax purposes violated the federal constitution was rejected.

Appellate Information

• Decided 07/07/2004
• Published 07/07/2004

Judges

• RUVOLO, J.

Court

• California Court of Appeal

Counsel

• For Appellant:
  
•  McDermott, Will & Emery, David L. Larson, Palo Alto, John G. Ryan and Lisa Sattler Blackburn, Menlo Park, for Plaintiff and Appellant.


• For Appellees:
  
• Bill Lockyer, Attorney General of the State of California, Randall P. Borcherding, Supervising Deputy Attorney General, Kristian D. Whitten, Deputy Attorney General, for Defendant and Appellant.