Laws can vary significantly in taxing multijurisdictional companies depending on a company\u27s degree of corporate presence in the taxing state, the type and source of income earned, and the type of property used or held in the state. Several critical factors can determine a company\u27s tax liability in a state, including the location of the company\u27s commercial domicile. The US Supreme Court\u27s decision in the Wheeling Steel case regarding commercial domicile is overriding in federal, as well as state courts. Accordingly, multistate companies and their tax advisors should consider the location of central management activities when planning to start or expand a business. Other factors contributing to the determination of commercial domicile also should be reviewed in considering locations for production, administration, and sales functions, in order to minimize the overall tax burden
