General Mills, Inc. v. Franchise Tax Board

*1294Opinion

BRUINIERS, J.

Under California’s version of the Uniform Division of Income for Tax Purposes Act (UDITPA; Rev. & Tax. Code, § 25120 et seq.),1 the portion of a national or multinational company’s income that is subject to taxation in this state is determined by a formula that compares the company’s payroll, property and sales in this state to its total payroll, property and sales. When the standard formula does not fairly represent the extent of the company’s business in California, however, UDITPA also provides for application of a reasonable alternate formula in order to achieve an…