Microsoft’s California Win Signals More Large Refunds to Come

March 1, 2024, 9:46 AM UTC

Microsoft Corp.'s $94 million win before the California Office of Tax Appeals regarding the treatment of repatriated income opens the door for a broad range of multinational companies to seek similar income tax refunds, tax practitioners say.

The number of companies and amount of refunds could be large. No similar cases are pending before the tax appeals office, but companies that regularly face similar issues in administrative proceedings with the Franchise Tax Board are likely to rely on the ruling to ask for refunds and change their position prospectively, they said.

“This is the most significant corporate income tax case ...

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