State and local tax specialists Stacey Roberts, CPA, and Judy Vorndran, J.D., CPA, take a close look at the impact of state and local taxation on multistate partnerships in this live 110-minute CPE webinar with interactive Q&A.

Thursday, October 31

11:00 am – 1:00 pm MT / 1:00 pm – 2:50 pm EDT

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

The character of partnership income, e.g., business or nonbusiness, 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 nonbusiness 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 both 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 when it comes to withholding or composite return obligations. Corporate tax professionals must know the complex rules to avoid adverse tax consequences in multistate partnership scenarios.

Our panel will provide tax advisers and professionals with a detailed and practical guide to critical state tax issues and trends impacting partners owning shares of multistate partnerships. The panel will discuss critical questions such as whether the character of pass-through income is determined at partner or partnership level, and whether the pass-through income must be considered on an “aggregate” basis or at the “entity” basis.

We will review these and other relevant matters:

  • Nexus implications
  • States that require business/nonbusiness income determination at partner vs. partnership level
  • Determination of partnership income on an aggregate basis vs. entity basis
  • Apportionment under the aggregate approach
  • Reconciling different states’ unitary factor analysis
  • State withholding
  • Recordkeeping, documentation, and workpapers

After our presentations, there will be a live Q&A session with participants so we can answer your questions about these important issues directly.

About the Speakers

Stacey L. Roberts, CPA
State and Local Tax Director
TaxOps

Ms. Roberts finds the singular state and local tax (SALT) area fascinating and is energized by the daily challenges to design solutions that improve business tax outcomes. With 20+ years of public and private sector accounting experience, both practical and in management, she’s gained the essential business acumen necessary to be a key advisor to clients. Ms. Roberts works closely with business clients managing all compliance issues related to state income/franchise, state and local sales and use, real and personal property and unclaimed property taxes for flow through entities and C corporations; identifying planning opportunities and state and local credits and incentives; and, mitigating state and local tax controversy issues with auditors and taxing jurisdictions.

Ms. Roberts is a frequent speaker and author on SALT issues for industry and professional organizations including the Denver Tax Institute, Product PowerUp, NowCFO and more.

Judith B. Vorndran, JD, CPA, MSBA
Partner
TaxOps

Ms. Vorndran helps clients and tax professionals navigate the morass of state and local tax issues with the goal of making it less taxing! She is a nationally recognized thought leader and award-winning instructor with a steady focus on finding ways to simplify complex state and local tax issues and resolve areas of state tax controversy.