Public Law 86-272 limits a state’s ability to impose income tax on out-of-state sellers whose only activities in the state consist of the solicitation of sales for tangible personal property. The statute doesn’t protect the solicitation of services or other industry types not dealing in sales of tangible personal property. However, many businesses in the manufacturing, distribution, and retail sectors have heavily relied on this protection over the years. Small and medium-sized businesses have arguably relied on the statute the most. More established companies have often branched out into service offerings related to the sales of property, such as repair and installation, sales of warrant
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