Microsoft Corp. v. Franchise Tax Board

Opinion

WERDEGAR, J.

Ours is a global economy. In contrast, government and the taxing authority used to fund it are national and local. This geographic disparity generates difficulties when each jurisdiction seeks its piece of the economic pie, a pie generated by economic activity that knows no borders.

The Uniform Division of Income for Tax Purposes Act (UDITPA) 1 attempts to address these problems and fairly assess corporate taxes. Adopted by the District of Columbia and 22 states, including California, it seeks to establish uniform rules for the attribution of corporate income, rules that in…