TEI Questions Constitutionality of California's Interest Offset Rule.
TEI has urged the California Supreme Court to review two cases involving the constitutionality of the State's so-called interest offset rule. In two cases pending before the court -- involving Hunt-Wesson, Inc. and F.W. Woolworth Co. -- the issue is whether the offset provision, which reduces a nondomiciliary company's interest expense deduction, dollar-for-dollar, for dividends received from nonunitary subsidiaries, discriminates against out-of-state companies and therefore violates both the Commerce and Due Process Clauses of the United States Constitution. On February 20, the Institute filed an amicus letter with the court, not advocating any...
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