USA State Income Tax: New York LLC Owned by Wyoming C Corp

[penelope]

Hello, I have a question which is probably for a CPA or accountant familiar with New York LLC tax law.

I need to form an LLC in the USA that will print, sell, and ship educational books. I am considering putting it in New York City (due to physical activities we will have in that area which may lead to many books being needed there).

I am considering the following structure:

1. A Wyoming C Corp (call it TSC Inc.) will be formed in Wyoming.
2. A New York LLC (call it CUS LLC) will be formed in New York.
3. TSC Inc. will be the sole owner of CUS LLC.
4. We will use the default form of taxation (pass-through taxation)
5. TSC will have physical nexus in New York, printing, storing inventory, and shipping from New York. It could rent an office space in New York, but it would not own or invest in real estate.

I understand that TSC Inc will pay corporate Federal Income Tax on the profits of CUS LLC.

And I understand that CUS LLC would pay sales tax and Franchise Tax to New York State.

The question is this:

Would TSC Inc. or CUS LLC pay any state income taxes to New York? Or will the state income tax flow through to the Wyoming Corp, so that TSC Inc. would pay Wyoming Corporate State Income tax on CUS LLC's income? (Which is 0%)

Thank you for any assistance.