Michael R. Gordon (J.D. 2011, North Carolina) has published Recent Development, Up the Amazon Without a Paddle: Examining Sales Taxes, Entity Isolation, and the Affiliate Tax, 11 N.C. J.L. & Tech. 299 (2010). Here is the abstract:

As a result of the Supreme Court’s decision in Quill v. North Dakota, unless a retailer has a physical presence in a state, it is not obliged to collect sales taxes in that state. In order to avoid collecting sales taxes, many companies like Amazon.com have set up subsidiary companies in many states to ship goods to customers but not sell them. This tactic is called entity isolation. On the other end of the spectrum, states are creating legislation, commonly but inaccurately called an 'affiliate tax,' which states that if a company makes a certain amount of money through affiliates in the state, it is deemed to have legal physical presence and is required to collect sales taxes. This Recent Development discusses how Quill has reacted to the Internet age, the possibility of states cutting through entity isolation, and the constitutionality of the so-called 'affiliate tax.'