Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

by | Aug 6, 2026 | ASC 740, Events, Federal Tax, R&D, State and Local, Tax Minimization, Tax News | 0 comments

TaxOps State and Local Tax Senior Manager Marc Gordon and Senior Tax Manager Benjamin Wirth will provide a detailed and practical guide to critical state tax issues and trends impacting partners owning shares of multistate partnerships

Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

Business vs. Non-business Income Characterization, Aggregate vs. Entity Determination, and More

Online Only | 2.0 Credits

Tuesday, September 1st | 11:00 AM MT, 1:00 PM ET

Register

Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

TaxOps State and Local Tax Senior Manager Marc Gordon and Senior Tax Advisor Benjamin Wirth will provide businesses and their tax advisers and professionals with a detailed and practical guide to critical state tax issues and trends impacting partners owning shares of multistate partnerships. They will discuss critical questions such as whether the character of pass-through income is determined at the partner or partnership level and whether the pass-through income must be considered on an “aggregate” basis or an “entity” basis.

Description

Corporate partners in multistate partnerships can’t escape nexus. Among the significant tax challenges these partnerships face is determining whether a partnership creates nexus for a nonresident partner. Nexus may materially impact filing obligations, including combined reporting and P.L. 86-272 positions and throwout and throwback rules.

The character of partnership income, e.g., business or non-business, also must be determined at the partnership level or the partner level. Very few states have issued any guidance on where to make the income determination, and those states that have addressed the question have mixed results.

Because business income must be apportioned, while non-business income must be allocated to the source state, taxation of partnership income varies from state to state. Additional complexities arise depending on whether a state has adopted the “aggregate” or “entity” approach to the apportionment of partnership income. These determinations may materially impact the computation of state blended rates for provision calculations and whether the corporation must remit payment to a particular state.

Likewise, various states have adopted different reporting regimes regarding withholding or composite return obligations. Corporate tax professionals must know the complex rules to avoid adverse tax consequences in multistate partnership scenarios.

Listen as our experienced tax experts offers a comprehensive view of states’ approaches to taxing corporations on multistate partnership income.

After the presentation, there will be a live question and answer session with participants to answer your questions about these important issues directly.

Instructors:

Marc Gordon
State and Local Tax Senior Manager

Marc Gordon brings over a decade of specialized experience in state and local tax to mid-market businesses across the country. With deep expertise in both income tax and sales and use tax, Marc serves as an outsourced SALT resource for CFOs, controllers and business owners who need a knowledgeable, hands-on partner to manager their most complex and pressing state and local tax challenges.


Marc’s technical range spans the full spectrum of state and local tax needs: income tax compliance, sales and use tax support, nexus and taxability analysis, exposure modeling, voluntary disclosure and amnesty programs, and audit and notice defense. He works across all industries, recognizing that businesses of every kind accumulate state and local tax exposure — and that finding it, resolving it, and charting a clear path forward is where he delivers the most value.

Benjamin Wirth
Senior Tax Manager

Ben Wirth is a senior tax manager with over 12 years of public and private experience in partnership and corporation tax issues. He manages the delivery of tax consulting services to a wide range of clients, focusing on flow-through entities, entity structure, and transaction planning.  Ben has prior experience with corporate compliance and income tax reporting under ASC 740. 

Ben provides strategic tax consulting services to businesses at all stages of the business life cycle, from start-up to liquidation, assisting with the analysis of taxable and non-taxable acquisitions, restructuring, monetizing events, and interpreting tax sections in partnership operating agreements.

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