A taxpayer that does not meet the bright-line presence standards may have substantial nexus in the state if its contact with the state is sufficient. It is the intent of the law to require businesses with a direct or indirect connection to the state to be subject to the franchise and excise tax to the extent allowed under the Constitution of the United States. For example, a business engaged in systematic and continuous business activity in the state that has produced receipts attributable to Tennessee customers will have substantial nexus with the state.
Reference: Tenn. Code Ann. § 67-4-2004(49).