The California Office of Tax Appeals (OTA) decided Appeal of Microsoft Corp. and Subsidiaries, No. 21037336, on July 27, 2023, and on February 14, 2024, rejected the California Franchise Tax Board’s (FTB’s) petition for rehearing. The facts of Microsoft are fairly straightforward. Microsoft, a water’s-edge return filer, repatriated $108 billion in dividends for the 2017 tax year in connection with the IRC Section 965 inclusion rules enacted by the Tax Cuts and Jobs Act.