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  5. 724 N.W.2d 526 (2006)
 

MANPOWER, INC. v. COMMISSIONER OF REVENUE

No. A06-468.

724 N.W.2d 526 (2006)

MANPOWER, INC., Relator, v. COMMISSIONER OF REVENUE, Respondent.

Supreme Court of Minnesota.

December 7, 2006.

Attorney(s) appearing for the Case

Mike Hatch, Attorney General, Catherine M. Keane, Assistant Attorney General, Bradford S. Delapena, Assistant Attorney General, State of Minnesota, Saint Paul, MN, for Respondent.

Walter A. Pickhardt, Lisa R. Pugh, Faegre & Benson, LLP, Minneapolis, MN, for Relator.

Heard, considered, and decided by the court en banc.

OPINION

HANSON, Justice.

Relator Manpower Incorporated (Manpower) is a Wisconsin corporation that operates, files a return, and pays taxes in Minnesota. In 1999 and 2000 (the tax years at issue), Manpower excluded the income of its wholly-owned subsidiary, Manpower France (MPF), from the net income it reported in its Minnesota income tax returns, pursuant to Minn.Stat. § 290.17, subd. 4(f) (2004), which states: "The net income and apportionment factors...

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