Illinois income tax nexus established by attributional nexus and sales tax registration, P.L. 86-272 protections exceeded

An Illinois Administrative Law Judge found that an out-of-state company had Illinois income tax nexus due to the in-state activities of third-parties and because of its sales tax registration with the state. While this unusual decision has no precedential authority, out-of-state taxpayers should be aware of the potential for Illinois to argue that income tax nexus may exist based on in-state activities of third-parties or merely because of registering for collection of sales tax.

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