Multistate Tax Treatment of Multi-Tier Partnerships: Navigating State Rules For Nonresident Tiered Pass-Through Entities

Webinar: ID# 1026349
Recorded CD or On-Demand
About This Course:
This webinar will provide tax advisers and compliance professionals with a practical guide to navigating the multistate reporting complexities involved in multi-tiered partnerships. The panel will outline various state rules governing apportionment of income from lower-tier pass-through entities, withholding requirements and composite return provisions. The panel will also discuss state approaches to honoring IRC 743(b) adjustments from the upper-tier to the lower-tier partnerships.

A significant challenge for tax advisers to tiered partnerships is determining various states’ tax treatment of the tiered entities, particularly when a lower-tier partnership is located in a different state than the upper-tier owner. Because of the inconsistency in various state treatments, tax advisers often face complex, sometimes conflicting, rules in determining how the upper-tier entity resident state will treat pass-through items of income and loss from lower-tier entities.

Advisers to upper-tier partnerships must determine how the entity’s lower-tier pass-through items are treated in the resident state. Ascertaining whether the lower-tier partnership’s apportionment factors flow through to the upper-tier entity materially affects the income/loss calculations of the partnership.

Likewise, navigating various states’ withholding requirements and determining when a lower-tier’s resident state allows, or mandates, composite filings is also a crucial and difficult task.
Tax advisers need to fully grasp the significant factors in determining various states’ tax treatment of multi-tier partnerships when the lower-tier partnership is non-resident.

Listen as our experienced panel offers a practical guide to navigating multistate complexities and approaches to taxing tiered partnerships with nonresident lower-tiers.

  • Identifying multi-tier partnerships with multistate filing requirements
  • How to determine whether lower-tier apportionment factors flow through to upper-tier partner
  • Withholding requirements
  • Composite return rules and exceptions for multi-tier partnerships

The panel will discuss these and other important questions:
  • Which states allow lower-tier partnership’s apportionment factors to flow through to the upper-tier partner?
  • How does the presence of a tiered partnership impact withholding requirements for nonresident partners?
  • Impact of a partnership’s status as a tiered entity on composite return requirements
  • What states allow tax attributes to flow through to the upper-tier partnership?
Learning Objectives

After completing this course, you will be able to:
  • Determine the circumstances and procedure in which filing a composite return may be advantageous to a pass-through entity and its partners.
  • Identify alternatives for withholding taxes of non-resident partners.
  • Ascertain whether a corporate partner of a pass-through entity operating in a foreign state will be considered to have nexus along with the pass-through entity.
  • Recognize state requirements for filing composite returns.
  • Verify whether a state taxes pass-through entity owners or both pass-through entity owners and the pass-through entity.
How To Access Course And Materials

Handout materials and the phone number for live presentations are made available to you one day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CDs will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Continuing Education Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. To obtain CPE credit, attendees must participate in the live event (recorded versions do not qualify for credit), return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Strafford will mail a certificate of credit within approximately two weeks of receiving your completed Official Record of Attendance, provided all required conditions have been satisfied.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.
Multistate Tax Treatment of Multi-Tier Partnerships: Navigating State Rules For Nonresident Tiered Pass-Through Entities
Available on CD or On-Demand formats
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