Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of Taxation

Among the limitations the Constitution sets on the power of a single State to tax the multistate income of a nondomicil-iary corporation are these: There must be “a ‘minimal connection’ between the interstate activities and the taxing State,” Mobil Oil Corp. v. Commissioner of Taxes of Vt., 445 U. S. 425, 436-437 (1980) (quoting Moorman Mfg. Co. v. Bair, 437 U. S. 267, 273 (1978)), and there must be a rational relation between the income attributed to the taxing State and the intrastate value of the corporate business. 445 U. S., at 437. Under our precedents, a State need not attempt to…