O'CONNELL, J.
Plaintiff appeals as of right an order granting summary disposition for defendant. We reverse. This case concerns the application of the Single Business Tax Act (SBTA), MCL 208.1 et seq., to foreign subsidiary, nonrepatriated earnings that the Internal Revenue Code (IRC), 26 U.S.C. 1 et seq., requires plaintiff to report as dividends on its federal income tax returns.
Plaintiff is an international financing company that controls...
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