As noted, it depends on each particular state.

Not only do you need to look at the filing requirements, but you need to review each states nexus standards.

While Quill and National Bellas Hess were specific when dealing with economic nexus (limiting this to sales and use tax only), the Wayfair decision was more broad.  This decision did not expressly differentiate between state income tax or sales and use tax when it changed the physical presence rule.  As a result, states are more likely to be more aggressive on their economic nexus standards.