The Pillsbury Co. v. Franchise Tax Bd.

Opinion

STEIN, J.

The Pillsbury Company (Pillsbury) appeals from a judgment granting the Franchise Tax Board’s (FTB) motion for summary judgment on Pillsbury’s complaint seeking a refund of California franchise taxes and interest for the income years June 1, 1985, to May 31, 1986, and June 1, 1986, to May 31, 1987. Pillsbury’s refund claim was based upon its assertion that California legislation, in 1987, adopted federal tax provisions that permitted Pillsbury to assign in excess of $168 million of its income to Alaska Native Corporation (ANC) subsidiaries in order to offset that income with…