ConAgra Brands v. Comptroller

ConAgra Foods RDM, Inc. v. Comptroller of the Treasury, No. 1940, September Term, 2015. Opinion by Woodward, J. TAXATION – INCOME TAX – CORPORATION INCOME TAX – TAXATION OF NON-DOMICILIARY CORPORATION – CONSTITUTIONAL REQUIREMENTS For a state to tax a non-domiciliary corporation, such taxation must withstand constitutional scrutiny under both the Due Process and Commerce Clauses of the United States Constitution. Although these clauses have different purposes and requirements, they have significant parallels. The Due Process Clause requires that (1) there be a minimal connection between the…