Reuven S. Avi-Yonah (Michigan; SSRN): Should Single-Sales-Factor Formulas Be Constitutional?, 119 Tax Notes State 683 (Mar. 2, 2026).
On October 28, 2025, Florida sued California in the Supreme Court over its application of a single-sales-factor (SSF) formula to exclude large out-of-state asset sales. But Florida couched its critique in much broader terms, seemingly attacking the validity of the SSF altogether.
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Is this complaint justified?
It is not, for many reasons. In this column, I will overlook some of these reasons and discuss Florida’s most interesting, if implicit, claim, namely that SSF is unconstitutional.
