Smithfield ruling- California apportionment
California apportionment factors that could potentially provide us with a strong case for substantial tax refund based on the recent court ruling (attached). Company formulates, blends, and distributes agricultural chemicals and solutions rather than directly cultivating crops, we have historically filed as a 100% manufacturer, mandating the use of the Single Sales Factor (SSF) for CA state tax return. Most recent C-corp tax return : filed under SSF at 8.67%. Historical S-corp years (full year returns): filed under SSF with a California apportionment factor reaching as high as 21% in 2023. In simple terms, this means we reported 21% of our total apportionable income as California-sourced and paid CA state tax on that portion. Smithfield Packaged Meats Corp tax ruling: The court ruled that enforcing the SSF method distorts income when an out-of-state taxpayer’s actual in-state economic substance (measured by property and payrol...