When does the ownership of a general partnership create franchise and excise tax nexus for its owner?

An owner of a general partnership that is “doing business in Tennessee and having substantial nexus” in the state must pay the franchise and excise tax if the owner is the type of entity that would generally be subject to the franchise or excise tax.  A general partnership is not itself a taxable entity, and it is treated as a division of its owner.  Therefore, to the extent that it is owned by an entity that is the type of entity that would generally be subject to the franchise or excise tax, its Tennessee activity is subject to tax.   For example, a corporation would be subject to the franchise and excise tax if its only connection to the state was its ownership interest in a general partnership doing business and having a substantial nexus in the state.

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