Multi-State Income Tax Nexus for Growing US Businesses: Beyond Sales Tax

See also our dedicated USSales.tax page on US Sales Tax.

Most growing US businesses eventually recognize they have multi-state sales tax obligations. Economic nexus thresholds, online sales platforms, and increased enforcement have made sales tax compliance impossible to ignore. What many businesses miss entirely is that sales tax represents only one dimension of multi-state tax exposure. Income tax nexus, franchise taxes, gross receipts taxes, and other state-level business taxes create separate filing obligations that often arise under different thresholds and through different activities than sales tax.

A business can be fully compliant with sales tax in all relevant states while simultaneously having unfiled income tax returns, unpaid franchise taxes, or unreported gross receipts in multiple jurisdictions. The triggers are different, the thresholds vary, the filing requirements don't align, and the discovery typically happens during due diligence, audit, or when attempting to dissolve an entity or obtain a tax clearance certificate for a transaction.

Understanding multi-state income tax exposure matters because the obligations are real, the penalties for noncompliance can be substantial, and the retroactive compliance process is far more complex than simply registering and filing going forward. Unlike sales tax, where you're collecting tax from customers and remitting it to states, income tax comes directly from your business profits. Getting it wrong means actual tax liability plus penalties and interest, not just compliance headaches.

For businesses operating across state lines through employees, contractors, property, or revenue-generating activities, multi-state income tax exposure is not a question of if but when and where. The challenge is identifying exposure before it becomes a problem and structuring operations to manage obligations efficiently rather than discovering them years later when the costs of addressing them have compounded.

What Income Tax Nexus Actually Means

Nexus is the connection between a business and a state that gives the state authority to impose tax obligations. For income tax purposes, nexus determines whether a state can require a business to file corporate income tax returns and pay tax on income apportioned to or derived from activities in that state.

The foundational principle comes from constitutional limitations on state taxation. A state can only tax businesses with sufficient connection to the state such that the tax doesn't violate due process or create an undue burden on interstate commerce. What constitutes sufficient connection has evolved through court cases, federal legislation, and state statutory changes over decades.

Physical presence traditionally created income tax nexus. A business with an office, warehouse, employees, or property in a state had nexus and filing obligations. This was relatively clear and predictable. If you had people or property in a state, you likely had income tax nexus there.

Economic nexus for income tax has emerged more recently and less uniformly than economic nexus for sales tax. Following the Supreme Court's decision in South Dakota v. Wayfair, which upheld economic nexus for sales tax, some states have implemented or expanded economic nexus standards for income tax. These standards create filing obligations based on revenue thresholds, transaction volumes, or other measures of economic activity in the state, regardless of physical presence.

The result is a complex patchwork where some states require income tax filing based on any physical presence, others use economic thresholds, some apply factor-based tests considering property, payroll, and sales, and a few have unique rules that don't fit standard categories. A business operating in ten states might have income tax nexus in seven of them under different theories and thresholds.

Public Law 86-272 and its Limitations

Public Law 86-272, enacted in 1959, provides federal protection from state income taxation for certain sales activities. If a business's only activity in a state is the solicitation of orders for tangible personal property, and those orders are approved and filled from outside the state, the state cannot impose net income tax on that business.

This protection has historically shielded many out-of-state sellers from income tax nexus in states where they conduct sales activities but have no other presence. A manufacturer in Ohio selling products to customers in California through traveling salespeople could rely on P.L. 86-272 to avoid California income tax filing obligations, provided the salespeople only solicited orders and all approvals and shipments occurred from Ohio.

The limitations of P.L. 86-272 are significant and frequently misunderstood. The protection applies only to net income taxes, not to gross receipts taxes, franchise taxes measured by capital or other bases, or sales and use taxes. It applies only to tangible personal property, not to services, digital products, or intangible property. It applies only when the sole activity is solicitation of orders, meaning any additional activities such as installation, training, technical support, market development, or maintaining inventory can destroy the protection.

The definition of solicitation has been interpreted narrowly. Activities that go beyond requesting purchases can exceed mere solicitation. Providing customer support, conducting repair services, maintaining demo equipment, recruiting employees, or engaging in market research can all create nexus beyond what P.L. 86-272 protects.

For modern businesses, particularly service businesses, software companies, and businesses with digital offerings, P.L. 86-272 provides no protection whatsoever. A consulting firm providing services in multiple states gets no benefit from P.L. 86-272. A software-as-a-service company has no protection. A business selling digital products cannot rely on it. The protection is limited to a specific type of business activity that represents a shrinking portion of the modern economy.

Even for businesses selling tangible personal property, relying on P.L. 86-272 requires careful attention to what activities actually occur in each state. The moment activities exceed pure solicitation, nexus exists and the protection disappears. Many businesses assume they're protected when they're actually not because they've failed to recognize activities that exceed the solicitation threshold.

Factor Presence and Economic Nexus for Income Tax

Many states have adopted factor presence standards that create income tax nexus when a business exceeds specified thresholds for property, payroll, or sales in the state. These thresholds vary widely but commonly include sales thresholds ranging from $50,000 to $500,000 or more, and sometimes include property or payroll thresholds as alternative or additional tests.

California, for example as at 2025 (check latest as FTB publishes updated annual thresholds), applies a bright-line test where exceeding $757,070 in sales, $75,707 in property, or $75,707 in payroll creates nexus (these amounts adjust annually). A business could have no physical presence in California but exceed the sales threshold through selling to California customers, thereby creating filing obligations.

New York uses an economic nexus standard for corporate franchise tax purposes based on receipts thresholds. : corporations are considered to be “deriving receipts” in NY if they meet the published receipts threshold, and NY states the actual threshold amount for specific tax years. NY’s own guidance shows $1.283 million in NY receipts for tax years beginning on/after Jan 1, 2024 and before Jan 1, 2027 (and related unitary group thresholds).

Other states have similar provisions with different dollar amounts and sometimes different methodologies for calculating whether thresholds are met.

The challenge is that each state applies its own thresholds, definitions, and calculations. Sales sourcing rules differ by state and by type of income. A service business needs to understand where its service revenue is sourced for each state's purposes, which can depend on where services are performed, where customers are located, where benefits are received, or other factors depending on the state and the service type.

Economic nexus for income tax creates particular issues for businesses that thought they were protected by P.L. 86-272 or believed they had no state tax obligations beyond sales tax. A software company selling subscriptions to customers nationwide can create income tax filing obligations in multiple states based purely on where customers are located and revenue sourced, with no consideration of physical presence or sales solicitation activities. The Supreme Court’s Wrigley decision is a key anchor for how “solicitation” and “ancillary” activities are treated. The Multistate Tax Commission’s statement (and its internet examples) is the modern “tripwire” list many advisors cite for website/chat/cookies and similar activities

Tracking whether economic nexus thresholds have been met requires systems that can attribute revenue by state according to each state's sourcing rules, monitor thresholds across multiple states simultaneously, and identify when registration and filing become necessary. Many businesses lack these systems and discover nexus only when preparing for transactions, facing audit, or attempting to obtain tax clearances.

Franchise Taxes and their Variations

Franchise tax is a separate category of state taxation that often confuses businesses because the term is used differently across states. In some states, franchise tax is essentially a corporate income tax under a different name. In other states, it's a tax measured by capital, net worth, or gross receipts rather than net income. Some states impose franchise tax in addition to income tax, while others use franchise tax as the primary business tax.

California's franchise tax is effectively a corporate income tax with a minimum tax component. Every corporation doing business in California or incorporated there must file and pay franchise tax, with a minimum tax of $800 annually regardless of income. Doing business in California is defined broadly and can include activities that don't rise to constitutional nexus for other purposes.

Delaware imposes an annual franchise tax on corporations incorporated there based on authorized shares or on assumed par value capital, not on income. Every Delaware corporation must file and pay franchise tax annually regardless of whether it conducts any business in Delaware or anywhere else. This catches businesses that incorporated in Delaware for perceived benefits but failed to realize that an annual franchise tax filing obligation exists perpetually until the entity is dissolved.

Texas has a franchise tax that is actually a gross receipts tax called margin tax, calculated on the lesser of total revenue times 70 percent, total revenue minus cost of goods sold, total revenue minus compensation, or total revenue minus $1 million. The calculation has nothing to do with net income. Businesses can be unprofitable and still owe Texas franchise tax because the tax is measured by gross receipts with certain deductions, not by net profit. Texas also has a “no tax due” revenue threshold (which changes over time). Many smaller entities file but owe no tax

Other states have franchise taxes measured by capital, net worth, or combinations of factors. The filing deadlines, thresholds, exemptions, and calculation methodologies vary dramatically. A business with nexus in multiple states may face franchise tax obligations in some, income tax obligations in others, and both in certain jurisdictions.

The interaction between franchise taxes and income taxes creates complexity in compliance. Some states allow credits between the two taxes so you don't pay both in full. Other states impose both independently. Understanding which taxes apply, how they're calculated, and how they interact requires state-specific knowledge that generic tax compliance systems often don't address adequately.

Gross Receipts Taxes

Several states impose gross receipts taxes that function differently from both income taxes and traditional sales taxes. These are taxes on gross revenue with limited or no deductions for costs, creating tax liability even for unprofitable businesses and imposing pyramiding effects when goods or services pass through multiple entities in a state.

Washington's Business and Occupation tax is a gross receipts tax imposed on the privilege of doing business in Washington. The tax applies to gross revenue from business activities, with different rates for different business classifications like retail, service, manufacturing, or wholesaling. There are no deductions for costs of goods sold, operating expenses, or other business costs. The tax is imposed on gross income, not net profit.

Ohio has a Commercial Activity Tax that was a gross receipts tax on businesses with significant nexus in Ohio. Ohio’s Department of Taxation maintains the CAT and (per their own page) for tax years 2025 and forward, only businesses with more than $6 million in Ohio taxable gross receipts owe CAT. Oregon has a Corporate Activity Tax imposed on commercial activity in Oregon exceeding $1 million in gross receipts. Nevada, Texas (as mentioned above under franchise tax), and Delaware (on gross receipts for certain business types) all have variations of gross receipts taxation.

These taxes create compliance obligations separate from income tax. A business can be subject to state income tax, state sales tax, and state gross receipts tax simultaneously in the same state. The filing deadlines, registration requirements, and payment schedules differ. The sourcing rules for determining what receipts are subject to tax vary by state and by type of receipt.

Gross receipts taxes are particularly painful for low-margin businesses because the tax applies regardless of profitability. A business operating on thin margins can face material gross receipts tax liability even in years where it has minimal or negative net income. This creates cash flow pressure and makes certain business models economically challenging in states with significant gross receipts taxes.

What Activities Create Multi-State Exposure

The activities that most commonly create unexpected multi-state income tax nexus involve people, property, or substantial economic activity in states beyond where the business is headquartered.

Having employees working remotely in other states is one of the most frequent triggers. A California-based software company that hires a software engineer working from home in Colorado has created Colorado nexus. The employer has property (the employee's home office equipment if provided by the company), payroll (the employee's compensation), and potentially sales (if the employee generates revenue or manages customer relationships). Even one employee can create nexus, though some states have de minimis thresholds.

Independent contractors can create nexus if they're functionally acting as employees or if they create sufficient presence through their activities. A business using contractors in multiple states to provide services, conduct sales, or manage operations may have nexus in those states depending on the nature and extent of the contractors' activities.

Owning or leasing property in a state creates nexus. This includes office space, warehouses, equipment, or inventory. Businesses using third-party logistics providers or fulfillment services need to understand whether they own the inventory stored in the 3PL's warehouse and whether that ownership creates nexus. In many cases it does, which means businesses using Amazon FBA or similar services may have nexus in every state where their inventory is stored.

Providing services in a state often creates nexus, particularly when the services are performed in the state by employees or contractors. A consulting firm sending consultants to client sites in multiple states for projects creates nexus in those states. An IT services company with technicians traveling to customer locations for installations or support work creates nexus where those activities occur.

Generating substantial revenue from customers in a state can create nexus under economic nexus provisions even without physical presence. The thresholds vary by state, but once exceeded, filing obligations arise. This particularly affects digital businesses, service providers, and companies selling into states where they have no offices or personnel but significant customer bases.

Attending trade shows, conferences, or conducting other temporary activities can create nexus in some states, though many states have exemptions for certain temporary presence. The rules vary, and businesses assuming that brief or occasional presence doesn't create nexus may be incorrect depending on the state and the specific activities conducted.

The Apportionment Question

Once nexus exists in multiple states, determining how much income is taxable in each state requires apportionment. Apportionment divides a business's total income among states based on formulas that consider where the business's property, payroll, and sales are located.

Most states historically used a three-factor apportionment formula weighing property, payroll, and sales equally or with sales double-weighted. Many states have shifted to single-sales-factor apportionment, where income is apportioned based entirely or primarily on where sales are sourced. This shift generally benefits states where businesses sell products or services while reducing tax in states where businesses have operations but fewer sales.

The apportionment methodology matters significantly for determining tax liability. A manufacturer with facilities in State A but customers primarily in States B and C will apportion more income to the customer states under single-sales-factor formulas than under three-factor formulas. A service business with employees in multiple states but customers concentrated in a few states faces different apportionment results depending on which states use which formulas.

Sales sourcing rules compound the complexity. For tangible property, sales are generally sourced to the destination state. For services, rules vary dramatically by state. Some states source service revenue to where the service is performed. Others source to where the customer receives the benefit. Some use where the customer is located. The same service sale can be sourced to different states depending on which state's rules are being applied for that state's apportionment purposes.

Market-based sourcing has become increasingly common, particularly for service businesses and businesses with intangible property. Market-based sourcing allocates sales to the state where the customer or market is located rather than where the service is performed or where the business has operations. This increases taxation in customer states and decreases it in operational states.

Combined reporting requirements in some states add another layer. Combined reporting requires affiliated entities to file as a unitary group, combining income and apportionment factors. This prevents income-shifting between related entities and can result in different tax outcomes than separate entity filing. Not all states require combined reporting, so a multi-state business might file separate entity returns in some states and combined returns in others.

When Businesses Discover Multi-State Tax Exposure

The most common discovery mechanism is due diligence in connection with financing, acquisition, or sale. Sophisticated investors and acquirers conduct tax due diligence that includes reviewing multi-state tax compliance. Questions about where the business has nexus, where it's registered, what returns have been filed, and what liabilities might exist surface quickly.

Businesses that have operated for years without filing in states where nexus exists face uncomfortable conversations during due diligence. The potential buyer or investor wants to understand the exposure, quantify potential liability including penalties and interest, and determine whether voluntary disclosure or other remediation is necessary before closing. This can delay transactions, reduce valuations through indemnification requirements or escrows, or in severe cases cause deals to fail entirely.

Tax authority audits in one state often lead to questions about other states. If a state audits your business and determines you have significant activities in other states, auditors may ask what filings exist elsewhere. Information sharing among state tax authorities has increased, meaning an audit in one state can trigger inquiries or audits in others.

Attempting to dissolve an entity or withdraw from a state requires tax clearances in many jurisdictions. A business that wants to close a subsidiary or foreign qualify status in a state where it no longer operates discovers it cannot obtain clearance without addressing unfiled returns and unpaid taxes. What was intended as a simple administrative cleanup becomes a multi-year compliance project to resolve historical obligations.

Registering for sales tax in a state sometimes triggers income tax questions. When completing sales tax registration applications, businesses often must answer questions about whether they have income tax filing obligations. Answering truthfully can require addressing unfiled income tax returns. Answering untruthfully creates false statement issues.

Some businesses discover exposure when key employees leave and new finance leadership reviews compliance. A CFO or controller joins a growing company and asks basic questions about state tax filings, only to discover that significant exposure exists because prior management didn't understand the obligations or actively chose to ignore them hoping they wouldn't be discovered.

Voluntary Disclosure Programs and Remediation

Most states offer voluntary disclosure programs that provide penalty relief and limited lookback periods for taxpayers who come forward before being contacted about noncompliance. These programs generally require that the taxpayer has not been contacted by the state about the tax in question, is not currently under audit, and has not been named in an information exchange or whistleblower complaint.

Voluntary disclosure typically limits the lookback period to three or four years rather than the full statute of limitations, which can extend much longer for unfiled returns. It eliminates or substantially reduces penalties for late filing and late payment. Interest generally still applies but accumulates over the shorter voluntary disclosure lookback period rather than from the first year nexus existed.

The voluntary disclosure process involves submitting an anonymous request through a third-party representative, providing information about the business and its activities, and negotiating terms with the state before identifying the taxpayer. Once terms are agreed, the taxpayer comes forward, registers, and files returns for the agreed lookback period.

For businesses with exposure in multiple states, voluntary disclosure can be conducted simultaneously across relevant jurisdictions. This is often the most practical approach when due diligence reveals significant multi-state noncompliance and the business needs to clean up exposure before closing a transaction or establishing proper compliance going forward.

The alternative to voluntary disclosure is either continuing noncompliance (which is illegal and creates growing exposure) or simply registering and beginning to file without addressing prior years. The latter approach leaves the statute of limitations open for unfiled years and provides no penalty protection. States can and do come back years later assessing tax, penalties, and interest for periods before registration.

Some businesses attempt to minimize exposure by arguing they lacked nexus in prior years even if nexus exists currently. This is risky and requires supportable factual and legal positions. If the state disagrees and determines nexus existed for years where no returns were filed, the penalties and interest can be substantially higher than they would have been under voluntary disclosure.

Structuring to Manage Multi-State Obligations

Businesses with significant multi-state operations often benefit from structural planning to manage where nexus exists and how income is apportioned. This doesn't mean artificial structures designed solely to avoid tax, but rather thoughtful entity design that reflects business operations while managing tax efficiency.

Using separate entities for different business lines or geographic regions can sometimes simplify compliance and provide flexibility in managing where nexus exists. A holding company structure with operating subsidiaries in key states can allow more targeted nexus management than a single entity operating everywhere.

Choosing where to locate employees, property, and operations has direct tax consequences. A business deciding where to open a new office or hire a regional team should consider the income tax implications of different states, not just employment costs and business factors. Locating operations in states with no corporate income tax or in states where the business already has nexus avoids creating new filing obligations.

The growth of remote work has created planning opportunities and challenges. Allowing employees to work from anywhere creates potential nexus in many states. Concentrating remote workers in specific states or limiting hiring in certain jurisdictions can manage nexus exposure, though this must be balanced against talent acquisition needs and operational requirements.

Using employee leasing arrangements or professional employer organizations can shift the employment relationship in ways that may affect nexus analysis, though this is complex and requires careful structuring to avoid creating nexus through the leased employees' activities despite the PEO relationship.

For businesses using independent contractors, ensuring true independence and documenting the contractor relationship properly helps prevent those contractors from creating nexus. This requires substantive independence, not just paperwork, but proper documentation supports the position if questioned.

The Administrative Burden of Multi-State Compliance

Beyond the tax cost itself, multi-state income tax compliance creates significant administrative burden. Each state has its own return forms, filing deadlines, payment requirements, and sometimes estimated tax payment schedules that don't align with federal or other state requirements.

A business with nexus in ten states may file a federal return, ten state returns, and possibly local returns in certain jurisdictions, each with different due dates, extension procedures, and payment requirements. Coordinating this across multiple states requires systems, processes, and often software solutions designed for multi-state compliance.

State tax authorities increasingly require electronic filing and payment. Registration for electronic filing systems varies by state. Some states use central portals while others have separate systems for income tax, sales tax, and other business taxes. Managing credentials, access, and filing across multiple state systems creates IT and administrative overhead.

Responding to state notices and inquiries becomes more complex with multi-state filings. States send notices about missing information, calculation questions, payment discrepancies, or proposed adjustments. Each notice requires review, response, and potential dispute resolution. With multiple states involved, the volume of notices and administrative correspondence can be substantial.

Estimated tax payment requirements in states often don't align with federal requirements or with each other. Some states require quarterly estimates based on prior year tax or current year projections. Others use different methodologies. Underpayment penalties for insufficient estimates vary by state. Managing cash flow to cover estimated payments across multiple states while avoiding underpayment penalties requires planning and monitoring.

Why Most Businesses Get This Wrong

The primary reason businesses fail to address multi-state income tax obligations proactively is simply that nobody tells them it's an issue. Sales tax gets attention because platforms, payment processors, and marketplaces require sellers to address it. Economic nexus for sales tax has been heavily publicized. Software providers focus on sales tax automation.

Income tax nexus receives far less attention, operates under different rules, and often isn't discussed until it becomes a problem. A business can operate for years without anyone raising the question of whether it has multi-state income tax filing obligations beyond its state of incorporation or headquarters location.

Many businesses assume that being registered for sales tax in a state means they're compliant with all state tax obligations. This is incorrect. Sales tax registration and income tax registration are separate. Being compliant with one doesn't address obligations for the other.

The complexity of the rules discourages proactive compliance. When filing requirements vary by state, thresholds differ, apportionment formulas aren't uniform, and determining nexus requires analyzing activities across multiple dimensions, many businesses simply don't undertake the analysis until forced to by due diligence, audit, or advisory engagement.

Some businesses actively avoid addressing known exposure, hoping states won't discover noncompliance. This is increasingly risky as information sharing among states improves, data analytics capabilities expand, and enforcement efforts increase. What might have gone undetected a decade ago is more likely to surface now.

The Changing Landscape

State revenue pressures and improved technology are driving increased multi-state tax enforcement. States have become more aggressive in identifying out-of-state businesses with nexus, using data from sales tax registrations, payment processors, third-party information reporting, and information sharing agreements with other states.

The shift to remote work accelerated by the pandemic has created massive new nexus issues as employees scattered geographically. States have responded by clarifying or modifying their rules around when remote employees create nexus. Some states have adopted temporary pandemic-related exceptions, while others have tightened enforcement.

Economic nexus expansion from sales tax to income tax represents an ongoing trend. While economic nexus for income tax is less uniform than for sales tax, more states are adopting or considering economic nexus standards. This trend will likely continue, creating filing obligations for businesses based purely on revenue thresholds regardless of physical presence.

Pass-through entity taxation has emerged as a new area of multi-state complexity. Many states now allow or require pass-through entities to pay entity-level tax in response to the federal $10,000 state and local tax deduction limitation. These PTE tax regimes create new filing obligations and require analysis of whether PTE tax elections make sense in each state where available.

Federal legislative proposals to create uniformity in state taxation or limit states' ability to tax remote work or digital commerce could reshape multi-state tax compliance, though such proposals face significant political obstacles. In the absence of federal action, the state-by-state complexity will likely persist and possibly increase.

Building Compliance Into Operations

For businesses serious about managing multi-state tax obligations properly, the work begins with understanding where nexus exists currently and establishing systems to monitor when new nexus is created through business expansion, hiring, or changes in operations.

A nexus study examines where the business has employees, property, contractors, sales, and other activities that might create filing obligations. This study should be conducted by specialists familiar with multi-state tax rules and should result in a clear analysis of where nexus exists, where it doesn't, and where it's uncertain or could be created by planned activities.

Ongoing monitoring requires building nexus considerations into operational decision-making. When hiring employees in new states, opening facilities, engaging contractors, or expanding into new markets, the tax implications should be analyzed before the activities begin rather than discovering them afterward.

Software and compliance tools can assist with multi-state income tax compliance, though they're generally less mature than sales tax automation tools. Understanding what software can and cannot do, and where human analysis remains necessary, prevents over-reliance on automation that doesn't address the full scope of obligations.

Working with specialists who understand multi-state taxation is essential for businesses with substantial multi-state operations. State income tax is sufficiently complex that general business accountants without multi-state expertise often miss issues or provide incorrect advice. The cost of specialized advice is far lower than the cost of getting it wrong.

Why does this matter now?

Multi-state income tax exposure is not a hypothetical risk for growing businesses. It's a present reality that materializes as soon as nexus is created through employees, property, or economic activity crossing state lines. The longer it goes unaddressed, the more years accumulate with unfiled returns, unpaid taxes, and growing penalties and interest.

For businesses planning to raise capital, pursue acquisition, or eventually exit, clean multi-state tax compliance is not optional. Due diligence will surface exposure, and addressing it during a transaction is far more costly and disruptive than handling it proactively before the transaction process begins.

The administrative burden and actual tax cost of multi-state compliance are real, but they're manageable when addressed systematically with proper structure, systems, and support. What's unmanageable is discovering ten years of unfiled returns across fifteen states during due diligence and attempting to remediate it under transaction timeline pressure.

Multi-state income tax is not something that only matters to large corporations or businesses with obvious multi-state operations. It matters to any business with employees working remotely, contractors in multiple states, customers creating economic nexus, or inventory stored in third-party facilities across state lines. For growing US businesses, understanding where these obligations exist and addressing them properly is fundamental to operating legally and positioning the business for sustainable growth and eventual successful exit.

References

• California Franchise Tax Board – Doing business in California (thresholds by year)

  https://www.ftb.ca.gov/file/business/doing-business-in-california.html

• New York State Department of Taxation and Finance – Deriving receipts for Article 9-A tax and MTA surcharge

  https://www.tax.ny.gov/bus/ct/article9a_deriving_receipts.htm

• New York State Department of Taxation and Finance – Instructions for Form CT-3 (mentions receipts threshold)

  https://www.tax.ny.gov/forms/current-forms/ct/ct3i.htm

• Ohio Department of Taxation – Commercial Activity Tax (CAT)

  https://tax.ohio.gov/business/commercial-activity-tax

• Texas Comptroller – Franchise Tax Overview (margin calculation methods)

  https://comptroller.texas.gov/taxes/publications/98-806.php

• Texas Comptroller – 2026 Franchise Tax Instructions (Form 05-915 PDF)

  https://comptroller.texas.gov/forms/05-915.pdf

• Washington Department of Revenue – Business & occupation (B&O) tax (gross receipts, no deductions)

  https://dor.wa.gov/taxes-rates/business-occupation-tax

• Oregon Department of Revenue – Corporate Activity Tax (CAT)

  https://www.oregon.gov/dor/programs/businesses/pages/corporate-activity-tax.aspx

• U.S. Supreme Court – Wisconsin Dept. of Revenue v. William Wrigley, Jr., Co. (P.L. 86-272 “solicitation” scope)

  https://supreme.justia.com/cases/federal/us/505/214/case.pdf

• Multistate Tax Commission – Statement on P.L. 86-272 (includes internet activity discussion)

  https://www.mtc.gov/wp-content/uploads/2023/04/025-MTC-Statement-on-PL-86-272.pdf

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