There are mortgage servicing operations located throughout the US that have a single physical location that "service" mortgages in several states. To service a mortgage loan means to collect monthly payments, pay property taxes and insurance on the real estate that secures the mortgage/deed of trust, enforce the terms of the mortgage/deed of trust on behalf of the investor who owns the mortgage/deed of trust and provide reports of these activities to investors.

All of the business activity is initiated and occurs in the single physical location. Several states are unclear as to whether they have taxable nexus and impose a franchise or similar non-income based tax. It is my opinion that these types of oprations are not subject to income tax apportioned or not. A franchise tax based on some apportionment factor applied to income is just an income tax in disguise.

A clear definition of what consitutes "doing business" or conducting activity that is taxable by a state or locality needs to be provided.