No.  If the (flow through) entity standing alone lacks nexus with the State of Michigan under the Due Process and Commerce Clauses of the U.S. Constitution, or under the statutory jurisdictional standards for activities protected under P.L. 86-272, the shareholders, partners, or other individual owners are not subject to Michigan income tax on their share of profits from the business activity.  The Michigan Income Tax Act, 1967 P.A. 281, MCL 206.1 - 206.532, does not provide for unitary groups or combined reporting with regard to personal income taxes, and apportionment must be determined on a separate entity basis.  For purposes of this determination, separate entities do not include entities disregarded for federal tax income purposes, such as federal Qualified Subchapter S Subsidiaries (Q-Subs) or unincorporated single member limited liability companies (SMLLCs).  Under MCL 208.1512, entities disregarded for federal income tax purposes are classified as disregarded for MBT purposes, except for certain exceptions described in the Department's Notice to Taxpayers Regarding Federally Disregarded Entities and the Michigan Business Tax, issued January 26, 2012.