I'm in the process of starting an Internet business, and am thinking about establishing the primary office for it in Connecticut. I am a New York resident. This would be an S-Corporation. Most likely I will incorporate in Delaware, but would file as a foreign corp in CT. I read the guidelines and examples in the instructions to Schedule CT-SI, but I am still unclear on the regulations regarding Connecticut-source income.

This company will be in the business of reselling tickets to entertainment and sporting events over the Internet. The web server that runs the website for the business will be located in the state of Kansas.

My question is, what would qualify as Connecticut-source income that the business would have to pay CT income tax on? I assume that if a transaction is made on the website where a seller outside Connecticut sells a ticket for an event outside Connecticut to a buyer outside Connecticut, there would be no Connecticut-source income generated in that scenario. So if this represented 100% of the business in a year, there would be no CT source income, correct?

What if there's a transaction where the seller is outside CT, but the buyer of the ticket is in CT? Is the profit the company earns on that considered CT-source income? And, vice-versa, if the seller is in CT but the buyer is outside CT, would the profit the company earns on that transaction be CT-source income?

To the extent there is any CT-source income, can I deduct that amount from my NYS tax return so that I'm not paying double taxes on the same income?