Presently, American states have the ability to impose taxes on multinational corporations doing business in their respective states. The extent of this imposition is vaguely regulated by federal tax law. In the Container decision, the Supreme Court addressed the need for uniformity of state taxation of foreign corporations. The Court's decision, however, was not well accepted overseas. This article examines the various methods of taxation employed by individual states and the resulting international difficulties of this diversity. Through a discussion of California legislation, which provides a solution, as well as protects domestic and foreign interests, these difficulties are addressed.
Massimo Agostini, U.S. Perspectives of Worldwide Unitary Taxation, 7 Penn St. Int'l L. Rev. 213 (1989).