Legal Opinion
Barclays Bank International Limited v. Franchise Tax Board
California Court of Appeal
Decided November 20, 1992No. C003388PublishedCited by 14 opinions
1Opinion of the Court
Opinion
DAVIS, J.
In this case we originally concluded that California’s unitary tax method of worldwide combined reporting (based on Rev. & Tax. Code, §§ 25101, 25120-25139), as applied to foreign-based unitary corporate groups, was unconstitutional under the foreign commerce clause in light of the “one-voice” component of judicially established dormant foreign commerce clause analysis. (U.S. Const., art. I, § 8, cl. 3; Japan Line, Ltd. v. County of Los Angeles (1979) 441 U.S. 434 [60 L.Ed.2d 336, 99 S.Ct. 1813]; Container Corp. v. Franchise TaxBd. (1983) 463 U.S. 159 [77 L.Ed.2d 545, 103…
2Cases cited52 opinions
- Grayned v. City of RockfordSupreme Court of the United States · 1972
- Hunt v. Washington State Apple Advertising CommissionSupreme Court of the United States · 1977
- Grayned v. City of RockfordSupreme Court of the United States · 1972
- Hoffman Estates v. Flipside, Hoffman Estates, Inc.Supreme Court of the United States · 1982
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
47 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Amaral v. Cintas Corp. No. 2California Court of Appeal · 2008
- Barclays Bank PLC v. Franchise Tax Bd. of Cal.Supreme Court of the United States · 1994
- J. H. McKnight Ranch, Inc. v. Franchise Tax BoardCalifornia Court of Appeal · 2003
- Jerron West, Inc. v. California State Board of EqualizationCourt of Appeals for the Ninth Circuit · 1997
- Farrar v. Franchise Tax BoardCalifornia Court of Appeal · 1993
9 more not listed; retrieve them via the Exa API.