An Exploration of State Income Tax Nexus: Does Economic Nexus Really Benefit States?

Abstract

ABSTRACT While considerable attention in the state taxation literature has been devoted to understanding how much of a corporation's income is subject to tax in a state, much less has been placed on understanding the more critical question of whether a corporation is subject to tax in a given state in the first place (Wildasin 2010). This study investigates the antecedents of state income tax nexus and the influence of economic nexus adoption on state corporate tax revenue collections with a two-stage least squares model using an instrumental variable approach and panel data from 2000–2009. The results of this model indicate that adoptions of economic nexus standards are more common in states with a weaker domiciled business group presence, consistent with interest group theory; adoptions are also more common among states with no required combined reporting, no NOL carryback provisions, the imposition of an alternative minimum tax (AMT), and a higher gross state product. Interestingly, after the first year of adoption, states that adopt economic nexus standards have no statistically significant difference in corporate tax revenue collections compared to those that follow a physical presence standard. In additional analyses, we determine that the interactive influences between diffusion and political factors and between diffusion and interest group factors also affect states' economic nexus adoptions. These results contribute to the taxation literature by suggesting that states' economic nexus standard adoptions are carried out for interest group, political, and regional diffusion reasons, and are not associated with any long-term discernible effects on state corporate taxation revenues. Data Availability: The data used in this study are available from public sources identified in the text and Table 2.