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Experts disagree on administrability and international backlash of ending water's edge election

Joint Informational Hearing of State Legislature (Senate/Assembly Revenue & Tax Committees) · February 11, 2026
AI-Generated Content: All content on this page was generated by AI to highlight key points from the meeting. For complete details and context, we recommend watching the full video. so we can fix them.

Summary

Academic witnesses argued recent federal and international reforms reduce compliance friction and can make worldwide combined reporting practicable; business and tax practitioners warned of double taxation, data gaps, compliance costs and litigation, especially for foreign‑parented firms.

A recurring theme at the hearing was disagreement among experts over whether California could practically and legally enforce mandatory worldwide combined reporting.

Professor Darren Shainski urged that income shifting is measurable, that many international reforms (GILTI/NICD, Pillar 2, CAMT) supply data or reporting that states could leverage, and that worldwide combined reporting is administrable for large firms. He argued that reasonable approximations…

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