Subsidiaries' Licensing of IP Rights to Parents Created Sufficient Taxing Nexus

Business Valuation UpdateVol. 9 No. 9
Legal and Court Case Update
September 2003

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2331 Women's, Misses', and Juniors' Blouses and Shirts
315210 Cut and Sew Apparel Contractors
state taxation (incl. ad valorem)
royalty rate, trademark, income tax
Comptroller v. SYL, Inc.
2003 Md. LEXIS 313
June 9, 2003
US
State Court
Maryland
Supreme Court
Eldridge

Summary

These consolidated cases concerned state income taxes of two corporations that did no business in Maryland but were subsidiaries of parents that did do business there.

See Also

Comptroller v. SYL, Inc.

Full Text of Court Cases
June 9, 2003

Issue is whether there is a sufficient nexus between the State of Maryland and each subsidiary corporation to impose Maryland income tax.