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State taxes on out-of-state businesses

ASAP Cruises v. Wisconsin Department of Revenue

Updated Nov 12, 2026

In brief

Where it stands
Dismissed

Petition denied.

What it’s about
ASAP Cruises asks whether a federal law limiting state corporate income taxes when a business only solicits sales in a state protects only sellers of physical goods, or also businesses that earn income another way, depending on their in-state activity.
Who it affects
ASAP Cruises did not get Supreme Court review, and the Court gave no answer in this case about which businesses the federal tax protection covers.

Summary: written with AI from the case record.

Illustration for ASAP Cruises, Inc., Petitioner v. Wisconsin Department of Revenue
Conceptual illustration · AI-generated

What it's about

Its filing relies on an earlier Supreme Court case, Heublein, for the broader reading.

P.L. 86-272 is a federal law that limits state corporate income taxes when a business only solicits sales in that state.

Question presented

Do the protections of P.L. 86-272 extend only to taxpayers that solicit sales of tangible personal property or—as held in Heublein—is the federal law concerned with the level of in-state business activity regardless of how the taxpayer earns its income?

Documents

1

Docket activity

7
  • New analysis added

    Nov 12, 2026 · Court records

  • AI analysis generated: Case Briefing

    Nov 12, 2026 · Generated

  • AI analysis generated: Decision Record

    Nov 12, 2026 · Generated

  • New analysis added

    Nov 11, 2026 · Court records

  • Case data updated: summary, question_presented, generation_metadata

    Nov 11, 2026 · Court records

Show 2 more
  • Case data updated: question_presented, extraction_metadata

    Nov 11, 2026 · Court records

  • Brief added: Petition

    Jul 13, 2026 · Court records

More questions

1
Did the refusal signal agreement with either side?
No. The refusal to hear the case was procedural and did not signal agreement with either side’s position.

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Nov 12, 2026Methodology

Court records and filings

Reporting and analysis