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Single Sales Factor Election May Create Exposure to Large Corporate Understatement Penalty in California

The California Franchise Tax Board recently released Legal Division Guidance 2012-03-02, concluding that taxpayers may not simultaneously report tax under a single sales factor elec

March 28, 2012

The California Franchise Tax Board recently released Legal Division Guidance 2012-03-02, concluding that taxpayers may not simultaneously report tax under a single sales factor election and the standard three-factor formula to avoid application of the Large Corporate Understatement Penalty. For full details, read our legal alert, "Single Sales Factor Election May Create Exposure to Large Corporate Understatement Penalty in California."

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Elizabeth S. Cha, Associate
Washington, DC
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