Foreign Entities Doing Business in the U.S. and Domestic Start-ups: Are you “Wayfair-aware?”

Foreign Entities Doing Business in the U.S. and Domestic Start-ups: Are you “Wayfair-aware?”

Setting the Stage Foreign Direct Investment benefits the United States as foreign companies build new manufacturing and research facilities, creating employment opportunities across the country.  Foreign companies are drawn to the U.S. by its large trading markets, educated workforce and stable political and business environments.  However, a trap for the unwary exists in the form of a disjointed and mostly-unaffiliated U.S. state and local tax regime; over 10,000 distinct tax jurisdictions exist within the U.S., each...

Wayfair and Factor-Based Nexus for Income Tax: The New Two-Step

Wayfair and Factor-Based Nexus for Income Tax: The New Two-Step

You’ve likely heard the expression “waiting for the other shoe to drop.”  By some accounts, the origin of this phrase can be traced to early 20th century tenement buildings where bedrooms on one story were located directly atop those on the lower story.  You knew when your upstairs neighbor came home because you could hear her shoe drop.  This left you waiting for the sound from the drop of the other shoe.    So it is...