In his Note, Beyond BA TSA: Getting Serious About State Corporate Tax Reform, Quinn Ryan provides us with the following: (1) an overview of the problem of diminishing state corporate tax revenues;2 (2) the basic legal principles applicable in administering state corporate income taxes;3 and (3) a history of the development of state tax nexus standards.4 Ryan uses the Business Activity Tax Simplification Act of 2009 (BATSA) to point out where reform is necessary and argues that BATSA is not the answer.6 While Ryan notes the myriad of problems with corporate income tax apportionment statutes 7 he leaves the mechanics of a uniform system for another Note .8 My only comment on apportionment, then, is that as an old Jeffersonian, I would prefer to see a state-by-state adoption of a uniform apportionment statute rather than having Congress federalize state tax codes with a mandated federal standard.



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