ON-DEMAND WEBINAR

A recent California Superior Court decision has opened the door for certain business taxpayers filing California income tax returns to request an alternative calculation of apportionment used for determining state taxable income. This creates a potential savings opportunity for multistate manufacturing, production, or capital-intensive businesses with little or no California property and payroll.

Watch members of CohnReznick’s State and Local Tax team for a focused discussion on what the Smithfield decision means for California income tax apportionment, which taxpayers may be impacted, and potential tax planning and refund strategies affected taxpayers should be evaluating and discussing in the wake of the decision. 

 Topics include: 

• Key takeaways from the Smithfield decision 
• When alternative apportionment may apply under California law 
• Which businesses may benefit most 
• Refund opportunities and protective claims for open years 
• The process for requesting alternative apportionment in California and examples of when approved 
• Implications for future California filings and potential opportunities in other jurisdictions 

Recorded on April 7, 2026.

SPEAKERS

Cindy Galamgam
Partner,

National Tax – State and Local Tax Practice 
 CohnReznick

Jaime Reichardt
Partner,

Practice Leader, State & Local Tax Services
CohnReznick

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