Director of Revenue v. Verisign, Inc.

Summary

The Court held that the Division of Revenue exceeded its statutory authority by limiting Verisign's Delaware net operating loss deductions to the consolidated deduction claimed by its federal filing group. Before the 2021 amendment, Delaware law required each corporation to calculate taxable income on a standalone basis, including its own allowable federal net operating losses. The Court invalidated the policy and struck the assessment, while declining to reach Verisign's constitutional claims.