that overruled the earlier holding of the Court of Appeals in Xerox Corp. v. Comptroller of Treasury, 290 Md. 126, 428 A.2d 1208 (1981), that dividend income could be taxed by the State if earned as part of the taxpayer’s unitary business. In fact, our review of ASARCO and other Supreme Court cases convinced us that the same analysis applied to dividend or interest income, the superficial form of the income being irrelevant and the real focus turning on the “economic realities” of the corporate transaction. Support for this position is found in other jurisdictions, where courts have focused on whether the investment income arose from the regular course of the taxpayer’s business. See, e.g., Silent Hoist & Crane v. Director, Division of Taxation, 100 N.J. 1, 494 A.2d 775, 783-86 (1985) (<HOLDING>); Lone Star Steel Company v. Dolan, 668 P.2d
recognizing as a substantial factor that the state in that case included dividends from the subsidiaries to the parent in its calculation of the parents apportionable taxable income but did not include the underlying income of the subsidiaries themselves holding a state cannot impose an income tax on indians whose income is solely from reservation sources recognizing that entities holding intellectual property for parent company had no real economic substance and allowing taxation of a portion of income attributable to parent corporations business in the state holding that corporations real estate investment activity was part of its unitary business and thus its portfolio income was correctly included in its apportioned income holding that there is no unitary business in part because there is no flow of international business