Microsoft Repatriated Income Ruling Stands After Reconsideration

The Oregon Tax Court declined Microsoft Corp.‘s request that it reconsider an earlier ruling about how to account for repatriated earnings for state income tax purposes, but clarified its reasoning.

The tax court ultimately didn’t change its conclusions or results from its 2024 ruling. There the court held that Microsoft could include 20% of its $159 billion in gross foreign dividends from repatriation in the calculation of its total income, but can’t increase the denominator of the apportionment fraction—used to determine what share of a company’s total income Oregon can tax—by the whole repatriation amount because it dilutes ...