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Legislators hold hearing on eliminating California’s ‘water’s edge’ election amid budget shortfall

Joint Informational Hearing of State Legislature (Senate/Assembly Revenue & Tax Committees) · February 11, 2026
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Summary

A joint Senate–Assembly informational hearing examined whether to require worldwide combined reporting rather than allow the water’s edge election; witnesses gave divergent estimates of revenue gains (low‑single‑digit billions to larger but uncertain figures), while agencies flagged data limits and administrative, litigation, and international risks.

California legislators held a joint informational hearing to reassess the state’s "water’s edge" election — the statutory option that lets some multinational corporate groups exclude much foreign subsidiary income from California combined reports — and to weigh proposals to require worldwide combined reporting.

Witnesses from the Legislative Analyst's Office and the Franchise Tax Board described how unitary taxation and apportionment work in practice: California uses a unitary approach that looks at related entities together and apportions taxable income to the state largely by the share of sales in California. The Franchise Tax…

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