The 50th Anniversary of
Public Law 86-272 - September 14, 2009 -
An odd milestone for temporary legislation!

In addition to highlighting the epic milestone of this temporary/stopgap legislation, this site provides background on P.L. 86-272 and links to information about current efforts to update and reform this rule dealing with state taxation of multistate businesses.

The issues surrounding updating and reforming this nexus provision are complex and hearings and discussions have occurred over the past few years. The discussions and debate are likely to last into the 113th Congress.

Blog post PL 86-272 History Legislative Proposals Other Proposals
Commentary - Business Commentary - Government Court Decisions and
 Income Tax Nexus Updates
UDITPA Rewrite Activity
Economic Nexus
  (what are states doing to fill void where PL 86-272 does not apply?
  Sales Tax Affiliate Nexus Website

Opportunity for comment and debate

P.L. 86-272 Links & History

Congressional Reform Proposals and Hearings

112th Congress

111th Congress

110th Congress

109th Congress

108th Congress

107th Congress

106th Congress

Other Nexus Reform Proposals

Commentary and Advocacy

Focus on Business Concerns

Focus on State Government Concerns



Court Decisions and Income Tax Nexus Updates

Opportunity for comment and debate

UDITPA Rewrite

NCCUSL (National Conference of Commissioners on Uniform State Laws) drafted the Uniform Division of Income for Tax Purposes Act (UDITPA) in 1957. It was last amended in 1966. UDITPA provides rules on apportionment and allocation of multistate business income among states. A committee was appointed to review Section 17 of UDITPA which deals with sourcing of sales that are not of tangible property.

NOTE: Efforts to reach uniformity in the apportionment and allocation of multistate income have been around for decades, as have efforts to find solutions. A 1982 GAO report on the issue concluded that Congress had to resolve the issues:


This page last revised on July 19, 2011.

Any views and opinions expressed in this page are strictly those of Professor Annette Nellen. The contents of this page have not been reviewed or approved by San Jose State University

Last Modified: Aug 14, 2018