Shiseido Cosmetics (America) Ltd. v. Franchise Tax Board
California Court of Appeal
[Opinion certified for partial publication.*]
1Opinion of the Court
Opinion
SUMS, J.
—In these cases consolidated for appeal, plaintiff Shiseido Cosmetics (America) Ltd. (SCA) sought refund of franchise taxes resulting from defendant Franchise Tax Board (FTB) assessments applying the unitary tax method of worldwide combined reporting (WWCR) (Rev. & Tax. Code, 1 § 25101 et seq.) based on the determination that SCA was engaged in a unitary business with Shiseido Co., Ltd. (Shiseido), its Japanese parent company, and Shiseido’s subsidiaries and affiliates located throughout the world. SCA claimed the application of WWCR violates the United States Constitution.
Both…
2Cases cited17 opinions
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