The out-of-state trucking company would have nexus with Michigan for purposes of the MBT if the company either picked up or delivered product in Michigan during 2 or more days within the tax year.  Furthermore, the company would have nexus with Michigan if the company merely drives through Michigan, i.e, travels through Michigan on a trip that originates and terminates outside of Michigan, with no pick up or delivery in Michigan and with no other business activity in Michigan, during 2 or more days within the tax year. 

If nexus is established, the taxpayer's business income and modified gross receipts tax bases must be apportioned by multiplying each tax base by the sales factor.  MCL 208.1301(1).  Generally, for an out-of-state transportation company, receipts from transportation services provided by the transportation company are sourced according to MCL 208.1305(11), (12) based on the ratio of revenue miles in Michigan (numerator) to revenue miles everywhere (denominator).  Revenue mile means the transportation for consideration of one net ton in weight or one passenger the distance of one mile.  MCL 208.1113(7).  Receipts from transportation services are combined with other receipts or sales of the taxpayer to compute the sales factor.  Note that once nexus exists in a tax year, then all revenue miles driven in Michigan, including revenue miles associated with "drive through" trips made in Michigan, are included in the apportionment formula numerator.  For an out-of-state transportation company that is a "foreign person" as defined in MCL 208.1207(8)(d) and is subject to MBT taxes, the sales factor is a fraction, the numerator of which is the taxpayer's total sales in Michigan where title passes inside the United States during the tax year and the denominator of which is the taxpayer's total sales in the United States where title passes inside the United States during the tax year.  MCL 208.1207(7).

Under MCL 208.1207(1)(i), however, a foreign trucking company domiciled in a subnational jurisdiction would not be subject to MBT taxes, notwithstanding the fact that it has nexus with Michigan for MBT, where that subnational jurisdiction does not impose an income tax on a similarly situated person domiciled in Michigan whose presence in the foreign country is the same as the foreign trucking company's presence in the United States.  Furthermore, if a subnational jurisdiction does not impose an income tax on businesses, but instead imposes some other type of subnational business tax, then the foreign trucking domiciled in that subnational jurisdiction is not subject to MBT taxes if that subnational jurisdiction's business tax is not imposed on a similarly situated person domiciled in Michigan whose presence in the foreign country is the same as the foreign person's presence in the United States.  MCL 208.1207(1)(i).