Alysse McLoughlin and Katie Quinn, partners on the state and local tax team in the New York office, authored the article “Moore Gives Taxpayers a ‘Gotcha’ Argument In Factor Representation Cases” published in the SALTy Thoughts section by Tax Notes State on September 9, 2024. In the article, Alysse and Katie discuss the Supreme Court’s decision in Moore v. United States and its implications for taxpayers, highlighting that the case’s rationale lends support for the argument that the factors of the foreign companies generating 965 income or GILTI must be included in the US shareholder’s state apportionment factor.