Vanderbilt Law Review


Paul J. Hartman

First Page



This Article explores the Supreme Court's treatment, leading up to and including the Container decision, of state taxation of corporate income from multinational operations. Part II highlights the Court's development, prior to 1982, of the basic principles of federal limitations on the states' taxing powers that guided its decision in Container. Part III takes a more detailed look at two 1982 Supreme Court cases, ASARCO, Inc. v. Idaho State Tax Commission and F.W. Woolworth Co. v. Taxation and Revenue Department, in which the states suffered a setback in their efforts to extend the reach of their taxing powers over income from multinational businesses. Part IV dissects the Container opinion, with a more in-depth explanation of the Court's analysis and the dissenters' response, and concludes with a discussion of the issues that the Container Court reserved for future decisions.