In the latest GeTtin’ SALTy podcast episode, host Nikki Dobay welcomes new Greenberg Traurig colleague John Ormonde, a shareholder in the firm’s State & Local Tax Practice.
The centerpiece of the episode is a detailed inside look at the Smithfield Foods case, which John identifies as one of the most significant California apportionment decisions in recent memory — and which observers at the Federation of Tax Administrators have called perhaps the single most important case on apportionment for the foreseeable future. John breaks down the two distinct issues before the court.
The first issue concerns whether Smithfield qualified as an agricultural business under California Revenue and Taxation Code Section 25128, entitling it to three-factor apportionment rather than single sales factor apportionment. The second and more broadly applicable issue involves alternative apportionment under Section 25137, California’s codification of Section 18 of UDITPA, which has counterparts in more… Read the complete article here...
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