State taxes on out-of-state businesses
ASAP Cruises v. Wisconsin Department of Revenue
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.

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
Docket activity
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AI analysis generated: Case Briefing
AI analysis generated: Decision Record
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Case data updated: summary, question_presented, generation_metadata
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Case data updated: question_presented, extraction_metadata
Brief added: Petition
More questions
- 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.