Search results
11 mar 2024 · In The Matter of the Appeal of Microsoft Corporation and Subsidiaries, OTA Case No. 210373336, the Office of Tax Appeals (“OTA”) decided that the taxpayer, Microsoft Corporation, was correct to include the entirety of its gross receipts from repatriated dividends in the denominator of its sales factor used for apportionment, regardless of ...
1 mar 2024 · Microsoft Corp.'s $94 million win before the California Office of Tax Appeals regarding the treatment of repatriated income opens the door for a broad range of multinational companies to seek similar income tax refunds, tax practitioners say.
28 lut 2024 · Two different panels of three administrative law judges rejected multiple arguments from the Franchise Tax Board that Microsoft can’t include $108.8 billion in gross foreign dividends from repatriation in calculating its taxable income in California compared to other states.
25 kwi 2024 · The California Office of Tax Appeals (OTA) decided Appeal of Microsoft Corp. and Subsidiaries, No. 21037336, on July 27, 2023, and on February 14, 2024, rejected the California Franchise Tax Board’s (FTB’s) petition for rehearing. The facts of Microsoft are fairly straightforward.
9 lis 2023 · The California Franchise Tax Board is asking the state’s tax tribunal to reconsider a preliminary decision giving Microsoft Corp. a $94 million income tax refund tied to its treatment of repatriated foreign earnings.
On December 18, 2012, the California Court of Appeal for the First Appellate District (“Court of Appeal”) issued its decision in Microsoft Corp. v. Franchise Tax Board 1 (“Microsoft”) reversing a lower court decision in favor of the Franchise Tax Board (“FTB”). In this case, Microsoft
17 sie 2006 · treasury operations provide a substantial portion of a taxpayer’s income, this exaggeration may result in an apportionment that does not fairly represent California business activity.
