This session will examine the United States Supreme Court decisions analyzing the "substantial nexus" standard of the Commerce Clause and the “minimum contacts” standard of the Due Process Clause of the United States Constitution and how these standards have been interpreted and developed by various state courts. The discussion will include the development of economic nexus and attributional nexus concepts. Finally, we will examine federal statutory limitations on a state’s ability to impose a net income-based tax on out of state businesses pursuant to P.L. 86-272 and selected cases interpreting this limitation.