Geoffrey, Inc. v. South Carolina Tax Commission
Supreme Court of South Carolina
1Opinion of the Court
Harwell, Chief Justice:
Geoffrey, Inc. (Geoffrey), a foreign corporation, appeals from a ruling that requires it to pay South Carolina income tax and business license fees. We affirm.
I. FACTS
Geoffrey is a wholly-owned, second-tier subsidiary of Toys R Us, Inc. (Toys R Us) incorporated in Delaware with its principal offices in that state. It has no employees or offices in South Carolina and owns no tangible property here.
In 1984, Geoffrey became the owner of several valuable trademarks and trade names, including “Toys R Us.” Later that year, Geoffrey executed a License Agreement (Agreement)…
2Cases cited13 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Shaffer v. CarterSupreme Court of the United States · 1920
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Curry v. McCanlessSupreme Court of the United States · 1939
- National Bellas Hess, Inc. v. Department of RevenueSupreme Court of the United States · 1967
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- Couchot v. State Lottery CommissionOhio Supreme Court · 1996
- General Motors Corp. v. City of SeattleCourt of Appeals of Washington · 2001
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