3--FATALE 105-142
PageMaker 6.5
Tax Lawyer, Vol. 54, No. 1 STATE TAX JURISDICTION 105 105 STATE TAX JURISDICTION AND THE MYTHICAL “PHYSICAL PRESENCE” CONSTITUTIONAL STANDARD Michael T. Fatale* “In today’s economy physical presence frequently has very little to do with a transaction a State might seek to tax.”1 I. INTRODUCTION The notion that the U.S. Constitution requires a corporation to be “physically present” in a state to be subject to that state’s tax has been a recent focus of legislators seeking to explicate the tax...