The reason this is relevant is the idea of "nexus and apportionment." Michigan deems a taxpayer to have "nexus" in the state if they are physically present in the state for more than one day, actively solicit sales in Michigan and thus have more than $350,000 in sales and have ownership in a flow-through entity that has presence in Michigan. Amstel easily qualifies on all three accounts and this means that there must be a calculation of apportionment for the sales done because not all of the sales would be taxable in Michigan, just those done in Michigan.

As for how Amstel can or should apportion their operations and sales, one can look at the prevailing corporate income tax rates for the relevant states. Michigan has a flat six percent on corporate income as of the first of 2013. Indiana is a bit higher at eight percent. Wisconsin is at...
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