MeadWestvaco Corp. v. Illinois Department of Revenue, 553 U.S. 16 (2008)
The decision in MeadWestvaco Corp. v.
Did Illinois exceed its constitutional authority by taxing MeadWestvaco's gain from the sale of Lexis/Nexis without establishing that Lexis/Nexis was part of a unitary business with substantial nexus to Illinois?
Under the unitary business principle, a state may tax an apportioned share of a corporation's multistate business income as long as the business in question forms part of a unitary business with substantial nexus to the state.
The Supreme Court held that Illinois could not tax MeadWestvaco's gain from the sale of Lexis/Nexis because the state failed to prove that the gain was derived from a unitary business operating within its jurisdiction.
This case is significant as it reinforced the boundaries regarding state taxation of out-of-state corporate activities. It clarified that a mere investment ownership does not constitute sufficient grounds for apportionable tax unless there's an operational nexus to the taxing state. For law students, the case highlights the constitutional principles limiting states’ tax powers, and it is a pivotal reference point in understanding how jurisdictional tax authority is determined.