In Geoffrey, Inc. v. South Carolina Tax Commission, 313 S.C. 15, 437 S.E.2d 13 (S.C. 1993), a subsidiary of Toys R Us, Inc. was the holder of Toys R Us trademarks.
Geoffrey, the subsidiary, had no offices or employees in South Carolina and did not own any tangible property there.
Geoffrey challenged the imposition of state income taxes on the ground that it had no substantial nexus with the state. 437 S.E. 2d at 15.
The court found a substantial nexus in the fact that Geoffrey licensed intangibles for use in the state and derived income from their use. Id.