Illinois Appellate Court Cites Professor Sarkar's UC Davis Law Review Article

The Illinois Appellate Court cited Professor Shayak Sarkar’s 2024 UC Davis Law Review article “Capital Migration” in PepsiCo, Inc. v. Department of Revenue.

The case involved Illinois’ 80/20 rule, which allows a unitary business group to exclude a member corporation’s income from combined Illinois income tax returns if 80% or more of the member’s property and payroll are generated outside the United States. The appellate court held that PepsiCo Inc. subsidiary Frito-Lay North America did not qualify as an 80/20 company.

Shayak Sarkar's scholarship addresses the structure and legal regulation of inequality. His substantive interests lie in financial regulation, employment law, immigration, and taxation.