Document Type

Amicus Brief

Publication Date


Case Name

New Hampshire v. Massachusetts


Professor Edward Zelinsky submitted an amicus brief with the U.S. Supreme Court in New Hampshire’s constitutional challenge against Massachusetts’s recently promulgated regulation imposing its income tax on nonresident remote workers, arguing that the Court should grant New Hampshire’s motion for leave because a state cannot source nonresidents’ income earned beyond the state’s borders; taxpayers have “no practical remedy” for relief from unconstitutional taxation under the Tax Injunction Act; and only the Court can make rulings over the boundaries of state authority.

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