S3027-119

To amend Public Law 86–272 to expand the prohibition of State taxation relating to certain solicitation of orders.

119th Congress

Legislative Progress

No timeline data available

Summary

What This Bill Does
This bill, the "Interstate Commerce Simplification Act," expands federal protections for out-of-state businesses from state income taxes. It broadens the definition of "solicitation of orders" under Public Law 86-272 to include any business activity that helps facilitate sales, even if that activity also serves other business purposes.

Who Benefits and How
- Out-of-state businesses and multistate corporations gain broader protection from state income taxes when selling into states where they have no physical presence.
- E-commerce and online retailers benefit from clearer protections for digital activities that facilitate sales across state lines.
- Companies with sales representatives gain protection for activities that go beyond pure order-taking but still relate to solicitation.

Who Bears the Burden and How
- State governments lose potential income tax revenue from out-of-state businesses whose activities would no longer create tax nexus.
- In-state businesses may face competitive disadvantages against out-of-state sellers who are protected from state income taxes.
- State tax agencies face reduced ability to tax economic activity occurring within their borders.

Key Provisions
- Amends Public Law 86-272 to expand the definition of "solicitation of orders"
- New definition covers any business activity that facilitates order solicitation, even if it also serves an independent business function
- Overturns state interpretations that narrowed the solicitation protection

Model: claude-opus-4-5
Generated: Dec 26, 2025 22:31

Evidence Chain:

This summary is derived from the structured analysis below. See "Detailed Analysis" for per-title beneficiaries/burden bearers with clause-level evidence links.

Primary Purpose

Expands the federal protection under Public Law 86-272 that limits state income taxation of out-of-state businesses by broadening the definition of 'solicitation of orders' to include business activities that facilitate solicitation, even if they also serve other business functions.

Policy Domains

Taxation Interstate Commerce Business

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Taxation Interstate Commerce
Actor Mappings
"states"
→ State governments seeking to tax out-of-state businesses

Key Definitions

Terms defined in this bill

1 term
"solicitation of orders" §2

Any business activity that facilitates the solicitation of orders even if that activity may also serve some independently valuable business function apart from solicitation

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology