GENERAL MOTORS CORPORATION et al., Plaintiffs and Appellants,
v.
FRANCHISE TAX BOARD, Defendant and Appellant.
Supreme Court of California.https://leagle.com/images/logo.png
August 17, 2006.
August 17, 2006.
Attorney(s) appearing for the Case
Ajalat, Polley & Ayoob, Charles R. Ajalat, Glendale, and Christopher J. Matarese for Plaintiffs and Appellants.
Morrison & Foerster, Eric J. Coffill and Carley A. Roberts, Sacramento, for Toys "R" Us, Inc., and Affiliates and The Limited Stores, Inc., and Affiliates as Amici Curiae on behalf of Plaintiffs and Appellants.
Pillsbury Winthrop, Jeffrey M. Vesely, San Francisco, Kerne H.O. Matsubara, Richard E. Nielsen and Annie H. Huang, San Francisco, for Council on State Taxation as Amicus Curiae on behalf of Plaintiffs and Appellants.
Nielsen, Merksamer, Parrinello Mueller & Naylor, John E. Mueller, Mill Valley, and Eric J. Miethke, Sacramento, for California Business Coalition as Amicus Curiae on behalf of Plaintiffs and Appellants.
Sutherland Asbill & Brennan and Kendall L. Houghton for Tax Executives Institute, Inc., as Amicus Curiae on behalf of Plaintiffs and Appellants.
Michael P. Boyle, Michael J. Bernard, Kurt A. Lamp; Preston Gates & Ellis, James P. Kleier, Brian W. Toman, Charles R. Zubryzcki; Baker & McKenzie and J. Pat Powers, Palo Alto, for Microsoft Corporation as Amicus Curiae on behalf of Plaintiffs and Appellants.
Bill Lockyer, Attorney General, W. Dean Freeman and Stephen Lew, Deputy Attorneys General, for Defendant and Appellant.
Frank Katz and Shirley Sicilian for Multistate Tax Commission as Amicus Curiae on behalf of Defendant and Appellant.
Supreme Court of California.
WERDEGAR, J.
Like many large companies, plaintiff General Motors Corporation has an active treasury department. Its treasury department supplements the company's other income-generating activities by investing the company's idle cash in short-term marketable securities. These investments present special analytical problems under the Uniform Division of Income for Tax Purposes Act (UDITPA),1 which California has adopted (Rev. & Tax...
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