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Maryland Tax Court narrowly defines 'solicitation' for protected personal property

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The Maryland Tax Court recently found that an out-of-state corporate taxpayer’s Maryland activities exceeded the solicitation of orders for tangible personal property protected under Public Law (P.L.) 86-272. In finding these activities sufficient to subject the entity to income tax, the Court concluded that when considered together, the activities were comparable to an in-state Maryland sales force rather than an out-of-state solicitation effort.