A taxpayer without a physical presence in the state may have substantial nexus in the state for franchise and excise tax purposes if it meets the bright-line presence definition of substantial nexus. The bright-line presence standards for substantial nexus operate such that if a taxpayer has at least $50,000 of property or payroll in the state, at least $500,000 of receipts in the state, or at least 25% of its total property, payroll, or receipts in Tennessee, it has substantial nexus with Tennessee without considering any other connections with the state.
Reference: ยง 67-4-2004(49).
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