Multistate Tax Alerts

Throughout the week, we highlight selected developments involving state tax legislative, judicial, and administrative matters. The alerts provide a brief summary of specific multistate developments relevant to taxpayers, tax professionals, and other interested persons. Read the recent alerts below or visit the archive.



Oregon Tax Court reconsiders decision on apportionment of Subpart F and dividend income

On October 6, 2021, in Oracle Corporation and Subsidiaries v. Oregon Department of Revenue, the Oregon Tax Court, Regular Division (Tax Court), reconsidered cross motions for partial summary judgment in a case involving dividend income and Subpart F income received by a taxpayer from its wholly-owned controlled foreign corporations (CFCs) and analyzed whether Oregon law required the portion of dividend income and Subpart F income that is not subtracted from federal taxable income through Oregon’s dividends-received deduction to be included in the taxpayer’s sales factor. Ultimately, the Tax Court reversed its earlier decision and determined that Subpart F income constitutes apportionable receipts and also denied both parties’ motions on the grounds that the remaining issue, determining the primary business activity of the taxpayer and its CFCs, was a factual matter.

This Multistate Tax Alert summarizes the Tax Court’s decision.
[Issued: November 15, 2021] More



Back to top