Lockheed Martin Corp. v. Hegar

This appeal arises at a first-impression intersection between our State's franchise-tax law and the federal laws that restrict the export of military articles from the United States to foreign nations. The pivotal issue concerns the proper "sourcing," for Texas franchise-tax-apportionment purposes, of receipts from Lockheed Martin Corporation's sales of fighter aircraft through "Foreign Military Sales" (FMS) transactions. FMS transactions, simply described, and as relevant here, entail the United States government's procurement from a domestic contractor of defense articles for resale to, and…