September 30, Death Date: January 26, Place of Birth: Although he did not invent chewing gum, it was his company that brought it to the world.
The opinion of the Court in No. This is a petition for writ of certiorari to the Supreme Court of Wisconsin. Between and the respondent, William Wrigley, Jr. Wisconsin orders were sent to Chicago for acceptance and were filled by shipment through common carrier from outside of Wisconsin.
Wrigley maintained that it was immune from the tax under Section a of Title 15 of the United States Code. That section prohibits a state from taxing the income of a corporation whose only business activities within the state consist of "solicitation of orders" for tangible goods. Provided that the orders are sent outside the state for approval and the goods are delivered from out of state.
Ultimately, the Wisconsin Supreme Court disallowed the tax. Obviously, the statutory phrase, "solicitation of orders", includes any speech or conduct that explicitly or implicitly proposes a sale.
We think it must mean more than that, however. If the statute is not to be rendered a practical nullity, solicitation must also cover the entire process associated with inviting an order.
On the other hand, the statutory phrase should not be interpreted so broadly as to include all activities that are routinely or even closely associated with solicitation or customarily performed by salesmen. In our view, solicitation of orders as used in Section a covers those activities that are entirely ancillary to requests for purchases, that is, those activities that serve no independent business function apart from their connection to the soliciting of orders.
Those activities that the company would have reason to engage in any way but simply chooses to allocate to its in-state sales force are not covered. We also conclude that there is a de minimis exception to the activities that forfeit the statutory immunity, the legal maxim de minimis non curat lex, the law does not take account of trifles.
Whether a particular activity is sufficiently de minimis to avoid the loss of the statutory immunity depends upon whether that activity establishes a non-trivial additional connection to the state. And because the vast majority of the gum stored by Wrigley in Wisconsin was used in connection with these activities, that storage and the indirect rental of space for that storage was in no sense ancillary to solicitation.
Moreover, these non-immune activities when considered all together are not de minimis. Accordingly, we conclude that Wrigley was not entitled to tax immunity under the statute and we, therefore, reverse the judgment of the Wisconsin Supreme Court.The William Wrigley Jr.
Company Case Report Ying Suan Lo Julianne Mills Nick Lim Vinson Chen Glen Hamilton Table of Contents Introduction Identifying opportunities for corporate financial restructuring was typical for Blanka Dobrynin, a managing partner of the hedge fund Aurora Borealis LLC.
The William Wrigley plombier-nemours.comy Case Report Ying Suan Lo Julianne Mills Nick Lim Vinson Chen Glen Hamilton Table of Contents Introduction Identifying opportunities for corporate financial restructuring was typical for Blanka Dobrynin, a managing partner of the hedge fund Aurora Borealis LLC.
In the case study, “The William Wrigley Jr. Company: Captial Structure, Valuation, and the Cost of Capital” the author, Robert Bruner, examines how Blanka Dobrynin, managing partner at Aurora Borealis, explores the opportunity to persuade Wrigley’s board to complete a leveraged recapitalization through a dividend or major share repurchase.
• Wm. Wrigley Jr. is an unleveraged company which canundertake $3 Billion dollars. • Wrigley was the world•s largest manufacturer and distributor of the chewing gum. • Wrigley•s stock price had significantly outperformed the S&P Composite index. William Wrigley, Jr., Company William H.
Rehnquist: The opinion of the Court in No. , Wisconsin Department of Revenue versus William Wrigley, Jr., Company will be announced by Justice Scalia.
Background Company - The William Wrigley Jr. Company The William Wrigley Jr. Company produces chewing gum and is the world’s largest manufacturer and distributor of this particular product. The industry that Wrigley operates in is distinguished by intense competition and is dominated by a few big companies/5(1).