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I'm in the process of starting an Internet business, and am thinking about establishing the primary office for it in Connecticut. I am a New York resident. This would be an S-Corporation. Most likely I will incorporate in Delaware, but would file as a foreign corporation in CT. This company will be in the business of reselling tickets to entertainment and sporting events over the Internet. The web server that runs the website for the business will be located in the state of Kansas. What would qualify as Connecticut-source income that the business would have to pay CT income tax on? I assume that if a transaction is made on the website where a seller outside Connecticut sells a ticket for an event outside Connecticut to a buyer outside Connecticut, there would be no Connecticut-source income generated in that scenario. So if this represented 100% of the business in a year, there would be no CT source income, correct? What if there's a transaction where the seller is outside CT, but the buyer of the ticket is in CT? Is the profit the company earns on that considered CT-source income? And, vice-versa, if the seller is in CT but the buyer is outside CT, would the profit the company earns on that transaction be CT-source income?


ANSWER


The BIDaWIZ Team's Answer:

The location of the buyer, seller or event doesn't have a bearing on your tax reporting requirements in other states as you don't have tax nexus there. In addition, the source of income is still technically Connecticut as that is where the administration occurs. Please reference Public Law 86-272. In conclusion, you would report the income on your tax return in CT and pay taxes in CT. However, you would also report it on your New York tax return & apply for a tax credit for taxes paid to CT so you aren't taxed on the same income.

The BIDaWIZ Team

 

 

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