No. 78-1201.

445 U.S. 425 (1980)


Supreme Court of United States.

Decided March 19, 1980.

Attorney(s) appearing for the Case

Jerome R. Hellerstein argued the cause for appellant. With him on the briefs were John Dwight Evans, Jr., and William B. Randolph.

Richard Johnston King argued the cause for appellee. With him on the brief was Gregory A. McKenzie, Deputy Attorney General of Vermont.

William D. Dexter argued the cause for the Multistate Tax Commission et al. as amici curiae urging affirmance. With him on the brief were the Attorneys General and other officials for their respective States as follows: J. D. McFarlane, Attorney General of Colorado; James Redden, Attorney General of Oregon; Jeff Bingaman, Attorney General of New Mexico; Carl R. Ajello, Attorney General of Connecticut; Albert R. Hausauer, Special Assistant Attorney General of North Dakota; Robert B. Hanen, Attorney General of Utah; David H. Leroy, Attorney General of Idaho, and Theodore V. Spangler, Jr., Deputy Attorney General; Paul L. Douglas, Attorney General of Nebraska; Edward G. Eiester, Jr., Attorney General of Pennsylvania; Mike Greely, Attorney General of Montana; Warren R. Spannaus, Attorney General of Minnesota; Richard Gebelein, Attorney General of Delaware; Avrum M. Gross, Attorney General of Alaska; and William J. Baxley, Attorney General of Alabama.*

MR. JUSTICE BLACKMUN delivered the opinion of the Court.

In this case we are called upon to consider constitutional limits on a nondomiciliary State's taxation of income received by a domestic corporation in the form of dividends from subsidiaries and affiliates doing business abroad. The State of Vermont imposed a tax, calculated by means of an apportionment formula, upon appellant's so-called "foreign source" dividend income for the taxable years 1970, 1971, and...

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