California Judges Affirm Tax on Janus Mutual Fund Receipts

Sept. 5, 2023, 10:10 PM UTC

The California Franchise Tax Board used the proper formula to assign receipts from Janus Capital Group’s mutual fund services to California when it denied the company’s claims for $4.2 million in refunds, the state Office of Tax Appeals said in an opinion posted Tuesday.

The office also affirmed its position that it lacks the authority to invalidate regulations from the state tax board, saying it won’t consider Janus’ argument that the tax board failed to follow the Administrative Procedure Act when it enacted the regulations at issue in the case. The opinion comes a month after the office’s director ...

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