Legal Upstreaming

by Derek G. Rowley (c) 2009. All Rights Reserved

Blogger Diane Kennedy, a CPA who graduated from the University of Nevada, Reno wrote a recent post on her website, TaxLoopholes.com, about legally upstreaming income. Diane points out several legitimate strategic uses of upstreaming strategies. I will use her four stated uses, and add my own commentary:

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Tax nexus principles for Trucking

Here are the basic principles of tax nexus for the trucking industry:

  • The state of Incorporation has automatic nexus
  • Trucking businesses provide a service, which is not a generally protected activity under Public Law 86-272
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