With no explanation, chose the best option from "A", "B", "C" or "D". Iowa Admin. Code 701-52.1(4)(422), Example 7 (Westlaw 2008); Mass. Dep'i of Revenue, Corporate Excise DOR Directive 96-2, July 3, 1996. 11 . See eg., 50, 605 S.E.2d 187, 195 (2004), cert. denied, 546 U.S. 821, 126 S.Ct. 353, 163 L.Ed.2d 62 (2005) (determining that "where a wholly-owned subsidiary licenses trademarks to a related retail company operating stores located within North Carolina, there exists a substantial nexus with the State sufficient to satisfy the Commerce Clause"); Tax Comm'r of State v. MBNA America Bank, 220 W.Va. 163, 640 S.E.2d 226, 234 (2006) (rejecting physical presence test and noting such a rigid interpretation of the Commerce Clause "makes little sense in today's world"); Comptroller of the Treasury v. SYL, Inc., 375 Md. 78, 825 A.2d 399, 415 (App.2003) (<HOLDING>); see also Surtees v. VFJ Ventures, Inc., 8

A: recognizing that entities holding intellectual property for parent company had no real economic substance and allowing taxation of a portion of income attributable to parent corporations business in the state
B: recognizing that third party may not recover contribution against parent where child has no cause of action against parent for negligent supervision
C: holding when real estate is conveyed to a child and consideration is paid by the parent the parent has the burden of proving a gift was not intended
D: holding that a parent company was not liable for aiding and abetting a breach of fiduciary duty by its subsidiary because the parent company was not a stranger to the business relationship between its subsidiary and the plaintiff giving rise to and underpinning the contract
A.