This comment will discuss the constitutionality of state use of the unitary method to tax multinational corporations. After considering the problems involved in allocating income between the jurisdictions in which a multinational corporation operates, the comment will examine the two predominant methods of allocation designed to solve these problems. The discussion will then analyze and criticize the Court's decision in Container Corp. v. Franchise Tax Board.
Bryan C. Skarlatos, States' Use of the Unitary Method: A Taxing Burden on International Commerce, 2 Penn St. Int'l L. Rev. 349 (1984).