Legal Opinion
Manpower, Inc. v. Commissioner of Revenue
Supreme Court of Minnesota
Decided December 7, 2006No. A06-468PublishedCited by 6 opinions
1Opinion of the Court
OPINION
HANSON, Justice.
Relator Manpower Incorporated (Manpower) is a Wisconsin corporation that operates, files a return, and pays taxes in Minnesota. In 1999 and 2000 (the tax years at issue), Manpower excluded the income of its wholly-owned subsidiary, Manpower France (MPF), from the net income it reported in its Minnesota income tax returns, pursuant to Minn.Stat. § 290.17, subd. 4(f) (2004), which states: “The net income and apportionment factors * * * of foreign corporations and other foreign entities which are part of a unitary business shall not be included in the net income or…
2Cases cited8 opinions
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Canada Southern Railway Co. v. GebhardSupreme Court of the United States · 1883
- Hutchinson Technology, Inc. v. Commissioner of RevenueSupreme Court of Minnesota · 2005
- Kmart Corp. v. County of StearnsSupreme Court of Minnesota · 2006
- Caterpillar, Inc. v. Commissioner of RevenueSupreme Court of Minnesota · 1997
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Gen. Mills, Inc. v. Comm'r RevenueSupreme Court of Minnesota · 2019
- Under the Rainbow Child Care Center, Inc. v. County of GoodhueSupreme Court of Minnesota · 2007
- HealthEast v. County of RamseySupreme Court of Minnesota · 2009
- Ashland Inc. v. Commissioner of RevenueSupreme Court of Minnesota · 2017
- Uline, Inc., Relator v. Commissioner of RevenueSupreme Court of Minnesota · 2024
1 more not listed; retrieve them via the Exa API.