In initial proceedings in which Lane Powell was not involved, the court ruled that a controlled foreign corporation’s Subpart F income included in a shareholder’s income is not a “gross receipt” of the shareholder for Oregon sales factor purposes, because the shareholder did not actually receive a distribution. On reconsideration, the court agreed with Oracle that gross receipts are based on the shareholder’s method of accounting so that Subpart F income is a gross receipt for Oregon sales factor purposes.