Cases & Deals

Multinational conglomerate protests California franchise tax

Clients Multinational conglomerate

Jones Day represented a multinational conglomerate in connection with its California franchise tax protests of certain unitary group composition and business/nonbusiness income determinations. The business/nonbusiness income issues generally center on taxpayer's distributive shares of income from numerous partnership investments and, thus, involve the subsidiary issue whether the partnerships are unitary with taxpayer disregarding ownership.