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The CFO of X, an SEC registrant (the Company), tells you that the Company is contemplating a sale of one of its reporting units, G,

The CFO of X, an SEC registrant (the "Company"), tells you that the Company is contemplating a sale of one of its reporting units, G, a wholly-owned subsidiary of the Company located in the Midwest. California law allows the Company to include G in its combined group for California state income tax purposes. Therefore G's receipts are currently included in the Company's calculation of its California sales apportionment factor. G has very few if any, California customers, and therefore the inclusion of G's activity in the receipts factor significantly dilutes the Company's California-resulting apportionment percentage. If the Company sells G, the California state apportionment factor will increase significantly (from 1% currently to approximately 14% post-sale) as it will no longer be diluted by G's receipts. The increase in the state apportionment factor will result in a higher effective California state income tax rate for the Company. The Company's existing California deductible temporary differences, which are expected to be recovered over the next five years, will not be reduced or otherwise affected by the sale of G. Therefore, the Company will still be able to utilize the deferred tax assets (DTAs) related to G in its California returns subsequent to the sale of G. The Board of Directors is expected to vote on the sale of G prior to June 30, 20x0 (the Company's fiscal year-end). If the Board approves the sale of G, it will be classified as held-for-sale as of June 30, 20x0.

  1. Identify what you believe is the most important fact to consider and why you believe it is the most important.
  2. Identify one question that you consider that is at a lower level of detail than the questions in the case.

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