Event Type: Webinar
Reed Smith’s State Tax Group will host a webinar on February 3 to discuss the implications of the California Supreme Court’s decision in Gillette. Specifically, we will discuss the following:
- Cert petition to the U.S. Supreme Court. Are there federal questions that make a cert petition likely? What are the chances that the Supreme Court will take the case, and what’s the timing?
- Should you withdraw your Gillette claims? Although the original “Compact Theory” is now in jeopardy in California, other theories may support your Gillette claim—especially as it relates to mandatory single sales factor apportionment. For example, does Proposition 39 (which mandates salesfactor-only apportionment) conflict with Proposition 26? Can a taxpayer still use the equally weighted “compact” formula to argue that other formulae (double weighted sales factor; sales factor only) are “distortive”?
- LCUP Risk. If you took the Gillette position on your original return, what is your exposure to the Large Corporate Understatement Penalty?
11:00 a.m. PT
2:00 p.m. ET