Hoechst Celanese Corp. v. Franchise Tax Board

*513Opinion

BROWN, J.

States have long struggled to devise an equitable and constitutional method for taxing corporations that do business in multiple states and countries. Like many other states, California has adopted the Uniform Division of Income for Tax Purposes Act (7A pt. 1 West’s U. Laws Ann. (1999) U. Div. of Income for Tax Purposes Act, § 1 et seq., p. 361) (UDITPA) in an attempt to resolve this dilemma (see Rev. & Tax. Code, §§ 25120-25141).1 Under this scheme of taxation, all taxpayer income is divided into business or nonbusiness income. Business income is apportion-able to each state…