Article
California Office Of Tax Appeals Rejects Unitary Business Treatment For Gain From Sale Of Company Division
The California Office of Tax Appeals examined whether a beverage distribution division operated as part of a unitary business with a taxpayer's other divisions, applying both the three unities test and the contribution and dependency test. The decision addresses critical questions about apportionability of income from asset sales and whether the tax benefit rule requires recovery of previously claimed deductions when operations are determined to be non-unitary.
Greenberg Traurig, LLP