Joyce v. Finnigan: Adoption of the "Best" Approach in Hopes of Some Uniformity

The Tax Lawyer -- The State and Local Tax Edition


In this comment, Lisandra Ortiz discusses the ongoing Joyce-Finnigan debate in the area of state taxation and apportionment of a multistate corporation's income. The issue "centers around the question of whose sales ought to be included in the sales factor numerator of a group of corporations subject to combined reporting, where some members of the group have nexus with the taxing state and other members do not." As she explores the debate in depth and argues that Joyce is the better rule, Ortiz provides the necessary context for the argument and traces the debate's origins from California to other jurisdictions.