:This case presented two questions. First, whether a foreign company, sole shareholder of an [[American]] subsidiary, has standing to challenge in federal court, on Foreign [[Commerce Clause]] grounds, the accounting method by which the State of [[California]] determines the locally taxable income of that subsidiary. Second, whether such a federal action for injunctive and declaratory relief is barred by the [[Tax Injunction Act]], 28 U.S.C. § 1341 (1982 ed.). | :This case presented two questions. First, whether a foreign company, sole shareholder of an [[American]] subsidiary, has standing to challenge in federal court, on Foreign [[Commerce Clause]] grounds, the accounting method by which the State of [[California]] determines the locally taxable income of that subsidiary. Second, whether such a federal action for injunctive and declaratory relief is barred by the [[Tax Injunction Act]], 28 U.S.C. § 1341 (1982 ed.). |