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Michigan tax tribunal finds passive holding company did not have nexus for Detroit income tax

On May 2, 2017, the Michigan Tax Tribunal granted a passive holding company’s motion for summary disposition and held that it did not have the requisite nexus with the city of Detroit for purposes of the City of Detroit Income Tax (CDIT). Although the company was “doing business” under the broad definition of the term contained in the City Income Tax Act, the company had no physical presence or minimum connection to Detroit. Furthermore, the tribunal determined that even though the company was part of a unitary business group that was based in Detroit, the company itself did not have nexus with the city for purposes of the CDIT.