Legal Opinion
International Business MacHines Corp. v. Department of Treasury
Michigan Supreme Court
Decided July 14, 2014No. Docket 146440PublishedCited by 42 opinions
1Opinion of the CourtViviano, J.
In this case, we must determine whether plaintiff International Business Machines Corporation (IBM) could elect to use the three-factor apportionment *645formula under the Multistate Tax Compact1 (the Compact) for its 2008 Michigan taxes, or whether it was required to use the sales-factor apportionment formula under the Michigan Business Tax Act (BTA).2 The Department of Treasury (the Department) rejected IBM’s attempt to use the Compact’s apportionment formula and, instead, required IBM to apportion its income using the BTA’s sales-factor formula.
We conclude that IBM was entitled to use the…
2Cases cited22 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Matsushita Electric Industrial Co. v. EpsteinSupreme Court of the United States · 1996
- Booth Newspapers, Inc v. University of Michigan Board of RegentsMichigan Supreme Court · 1993
- United States Steel Corp. v. Multistate Tax CommissionSupreme Court of the United States · 1978
- Rathbun v. State of MichiganMichigan Supreme Court · 1938
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3Cited by42 opinions
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- Lisa Tyra v. Organ Procurement Agency of MichiganMichigan Supreme Court · 2015
- Mich. Gun Owners, Inc. v. Ann Arbor Pub. Sch.Michigan Supreme Court · 2018
- Graphic Packaging Corp. v. HegarTexas Supreme Court · 2017
- Gillette Commercial Operations North America & Subsidiaries v. Department of TreasuryMichigan Court of Appeals · 2015
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