Summary
The South Carolina Supreme Court ruled in Geoffrey, Inc. v. South Carolina Tax Commission that the physical presence test applied by the US Supreme Court in Quill Corp. v. North Dakota only applied to state sales and use taxes. South Carolina was attempting to tax income of a Toys R Us Corp. subsidiary established solely to license trademarks and collect royalties. The Court in Quill found that a substantial physical presence in the state was required for state corporate taxation, but the Court did not explicitly limit this nexus test to certain types of tax.
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Extract
Nexus through the presence of intangibles.
Most corporate taxpayers are familiar with the Supreme Court's decision in Quill Corp. v. North Dakota, 112 Sup. Ct. 1904 (1992), in which the Court held that a mail-order seller could not be required to c...
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