Iowa Admin. Code 701-52.1(4)(422), Example 7 (Westlaw 2008); Mass. Dep'i of Revenue, Corporate Excise DOR Directive 96-2, July 3, 1996. 11 . See eg., 50, 605 S.E.2d 187, 195 (2004), cert. denied, 546 U.S. 821, 126 S.Ct. 353, 163 L.Ed.2d 62 (2005) (determining that "where a wholly-owned subsidiary licenses trademarks to a related retail company operating stores located within North Carolina, there exists a substantial nexus with the State sufficient to satisfy the Commerce Clause"); Tax Comm'r of State v. MBNA America Bank, 220 W.Va. 163, 640 S.E.2d 226, 234 (2006) (rejecting physical presence test and noting such a rigid interpretation of the Commerce Clause "makes little sense in today's world"); Comptroller of the Treasury v. SYL, Inc., 375 Md. 78, 825 A.2d 399, 415 (App.2003) (<HOLDING>); see also Surtees v. VFJ Ventures, Inc., 8
holding when real estate is conveyed to a child and consideration is paid by the parent the parent has the burden of proving a gift was not intended recognizing that third party may not recover contribution against parent where child has no cause of action against parent for negligent supervision 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 a parent company was not liable for aiding and abetting a breach of fiduciary duty by its subsidiary because the parent company was not a stranger to the business relationship between its subsidiary and the plaintiff giving rise to and underpinning the contract recognizing that a foster parent may attain the status of psychological parent when the relationship is not temporary in duration and exists with the consent and encouragement of a childs legal parent or guardian