Exxon Mobil Corp. v. Montana Department of RevenueAnnotate this Case
The Supreme Court reversed the order of the district court denying Exxon Mobil Corporation's (ExxonMobil) petition for interlocutory adjudication and affirming the Department of Revenue's determination that ExxonMobil was entitled to an eighty percent exclusion from income for the dividends it received from several of its domestic subsidiaries, holding that ExxonMobil correctly excluded 100 percent of the actual dividends.
On appeal, ExxonMobil argued that the district court erred when it concluded that the dividends at issue were expressly apportionable as income under Mont. Code Ann. 15-31-325 and that, therefore, ExxonMobil was not entitled to a 100 percent income exclusion under Internal Revenue Code (I.R.C.) 243. The Supreme Court reversed, holding that ExxonMobil may deduct the actual dividends it receives from the domestic subsidiaries at issue for purposes of Montana taxation through I.R.C. 243.