From Japan Line to Barclays: The Rise and Fall of the Foreign Commerce Clause
7 State Tax Notes 379
The Supreme Court's recent decision in Barclays Bank PLC v. Franchise Tax Board, which
upheld the constitutionality of California's worldwide combined reporting method of
apportionment, had some unusual features for a case involving the arcana of state taxation. The
enormous amount of money involved -- estimates of California's potential refund liability ran
(somewhat improbably) as high as $4 billion -- guaranteed wide attention for the case in the press.