Geoffrey, Inc. v. South Carolina Tax Commission

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the physical presence requirement of Quill has not been extended to other types of taxes such as taxes on royalty income
• holding that tax imposed on income derived from license fee met the substantial nexus test
• holding that the physical presence requirement of Quill has not been extended to other types of taxes, such as taxes on royalty income
• holding that an out-of-state trade mark holding company was subject to the state’s taxing jurisdiction because it earned income based on the franchise activities in the state
• holding that “by licensing intangibles [to Toys ’R Us, an affiliated operating store,] for use in [South Carolina] and deriving income from their use [t]here, Geoffrey ha[d] a ‘substantial nexus’ with South Carolina”
• holding that by licensing intangibles for use in South Carolina, holding company had substantial nexus, such that taxing royalties from intellectual property would not violate the dormant Commerce Clause

Source: CourtListener parenthetical corpus (CC0).