Detail about COMPTROLLER OF THE TREASURY OF MARYLAND v. WYNNE et ux
The "four-prong test" refers to the criteria established by the U.S. Supreme Court in the case of Complete Auto Transit, Inc. v. Brady, 430 U.S. 274 (1977), which is used to evaluate the constitutionality of state tax laws under the Dormant Commerce Clause. The Dormant Commerce Clause is an implied restriction in the U.S. Constitution that prohibits states from enacting legislation that discriminates against or excessively burdens interstate commerce. To pass the four-prong test, a state tax must meet all of the following criteria: 1. **Substantial Nexus**: The tax must apply to an activity with a substantial nexus, or connection, to the taxing state. This means the entity being taxed must have a significant presence or business activity within the state. 2. **Fair Apportionment**: The tax must be fairly apportioned so as not to tax activities beyond the borders of the state. It should not lead to double taxation of the same income or value by different states. 3. **Non-Discrimination**: The tax must not discriminate against interstate commerce. This means it should not impose a burden on out-of-state businesses or transactions that is not also imposed on in-state businesses or transactions. 4. **Fair Relationship to Services Provided**: The tax must be fairly related to the services provided by the state. There should be a reasonable relationship between the tax imposed and the benefits provided by the state to the entity being taxed. If a state tax fails to
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