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Last year, the United States Supreme Court issued a landmark state taxation decision in South Dakota v. Wayfair, 585 U.S. ___ (2018), overturning the “physical presence” test under Quill Corp. v. North Dakota, 504 U.S. 298 (1992). On June 21, 2019, the one-year anniversary of Wayfair, SCOTUS held that part of Quill lives on. In N.C. Dep’t of Revenue v. The Kimberly Rice Kaestner 1992 Family Trust, 588 U.S. ___ (2019), the court unanimously upheld the “minimum contacts” test under Quill as it applies to state taxation of income earned by a trust.

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