Iowa Department of Revenue Policy Letter, No. 11201006 (Apr. 14, 2011)

(Iowa nonresident sold stock in Iowa-based family S-corporation to create ESOP; IDOR views creation of ESOP as resulting in stock attaining independent business situs because stock used as integral part of business activity occurring in Iowa via creation of ESOP; capital gain earned by nonresident considered Iowa source income; no indication given as to where outer limit of such standard is located; current regulations do not require such standard).