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If a taxpayer elects to calculate its net worth on a consolidated basis, which members of the affiliated group are subject to franchise and excise tax?

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If a taxpayer elects to calculate its net worth on a consolidated basis, which members of the affiliated group are subject to franchise and excise tax?

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Only the entities that are doing business in Tennessee or exercising the corporate franchise are subject to the franchise and excise tax. The election to compute net worth on a consolidated basis does not affect the entity’s nexus in the state. Only the method of calculating the franchise tax is different for that entity and the other taxpayers in the group with nexus in the state. Taxpayers who are subject to the franchise tax before electing to calculate their net worth on a consolidated basis are still required to file their own franchise and excise tax returns.

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