Business Income

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On October 28, 2025, Florida filed a motion for leave to file a bill of complaint in the United States Supreme Court challenging California’s business income tax apportionment regulation, alleging it unconstitutionally discriminates against out-of-state corporations. The case invokes the Court’s original jurisdiction over disputes between states, a mechanism reserved for matters of sufficient seriousness…

In Department of Taxation v. FJ Management, Inc., the Virginia Court of Appeals recently concluded that the apportionment factors of a partnership in which a taxpayer held a minority interest could not flow up to the partner because there was no unitary relationship between the partner and the partnership. As state scrutiny over apportionment…