OPINION BY JUSTICE WILLIAM C. MIMS
In this appeal, we consider the extent to which a corporate taxpayer must include in its Virginia taxable income royalties paid to an intangible holding company.
I. Background and Procedural History
Kohl's Department Stores, Inc. ("Kohl's") is a corporation organized under the laws of Delaware. It operates retail stores throughout the United States, including Virginia. Kohl's Illinois, Inc. ("Kohl...
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