Geoffrey Sidesteps Quill: Constitutional Nexus, Intangible Property and the State Taxation of Income

This article evaluates the correctness of the decison in Geoffrey, Inc. v. South Carolina Tax Commission, 437 S.E.2d 13 (S.C.), cert. denied, 510 US 992 (1993), which held that the "physical presence" standard for determining state tax jurisdiction, as articulated in Quill Corp. v. North Dakota, 504 U.S. 298 (1992), does not apply in the context of a corporate income tax.