Cite as: 512 U. S. 298 (1994)
Opinion of the Court
§ 22. See Cal. Rev. & Tax. Code Ann. § 25110 (West Supp. 1994). The new amendments became effective in January 1994.
C
The first of these consolidated cases, No. 92-1384, is a tax refund suit brought by two members of the Barclays Group, a multinational banking enterprise. Based in the United Kingdom, the Barclays Group includes more than 220 corporations doing business in some 60 nations. The two refund-seeking members of the Barclays corporate family did business in California and were therefore subject to California's franchise tax. Barclays Bank of California (Barcal), one of the two taxpayers, was a California banking corporation wholly owned by Barclays Bank International Limited (BBI), the second taxpayer. BBI, a United Kingdom corporation, did business in the United Kingdom and in more than 33 other nations and territories.
In computing its California franchise tax based on 1977 income, Barcal reported only the income from its own operations. BBI reported income on the assumption that it participated in a unitary business composed of itself and its subsidiaries, but not its parent corporation and the parent's other subsidiaries. After auditing BBI's and Barcal's 1977 income year franchise tax returns, the Tax Board, respondent here, determined that both were part of a worldwide unitary business, the Barclays Group. Ultimately, the Tax Board assessed additional tax liability of $1,678 for BBI and $152,420 for Barcal.6
6 The figures used by the Tax Board were:
| Taxpayer | Worldwide Taxable Income | California Formula Percentage | Business Income | Franchise Tax |
| Barcal | $401,566,973 | .0139032% | $5,583,066 | $693,696 |
| BBI | 401,566,973 | .0003232% | 129,786 | 16,126 |
App. in No. 92-1384, pp. A-13 to A-14 (Joint Stipulation of Facts ¶ 22).
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