A foreign corporation is subject to the Massachusetts corporate excise tax if it owns or uses intangible property within the state, provided that the activity through which it obtains gross receipts from its intangible property is purposeful and its presence in the state is more than de minimis. The directive outlines three criteria for nexus: the intangible property generates gross receipts within the state, the corporation's activity with respect to the property is purposeful, and its presence in the state is significant.