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Surgent's Multistate Tax: Issues for Pass-Through Entities (MTPE)
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Partnerships and other pass-through entities present a multitude of state income tax complexities and opportunities. This update will address some of the state income and franchise tax opportunities and risks associated with LLC and partnership structures as well as the different methods to apportion or allocate income from these types of entities. Some of the issues facing corporate partners such as assertion of nexus and determining apportionment factors when a corporate partner has transactio

11/17/2015
When: 11/17/2015
11:00 AM - 1:00 PM
Where: Webcast/Webinar
Presenter: Pam Davis-Vaughn, CPA
Contact: April Deneault
801-834-6634


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Partnerships and other pass-through entities present a multitude of state income tax complexities and opportunities. This update will address some of the state income and franchise tax opportunities and risks associated with LLC and partnership structures as well as the different methods to apportion or allocate income from these types of entities. Some of the issues facing corporate partners such as assertion of nexus and determining apportionment factors when a corporate partner has transactions with a partnership will also be discussed.

Objectives:

* Understand the sourcing of partnership income * Determine issues with partnerships and pass-through entities that could give partners as well as the partnership nexus in a state * Identify developing state issues relative to partnership and LLC interests

Major Subjects: 

* Partnership state issues: Withholding and composite returns; States and localities that impose a tax on the partnership; Taxation on both the partnership and partner; Gross receipts tax on partnerships * Nexus issues: Owning interest in a partnership operating in the state; Exceptions; Investment partnerships; Does ownership of partnership interest exceed protection under P.L. 86-272?; Does ownership of a partnership interest create nexus so that Throwback does not apply? * State Sourcing of Partnership Income: No apportionment Factor Flow Up - (Non unitary method); Flow up Income and Apportionment Factors - (Unitary method); Special Rules for Investment Partnerships; Intercompany Transactions * Nexus issues from Factor Flow up: Does a partner's nexus in the state create nexus for the partnership? * Sale of a partnership interest: Treated as sale of an intangible; Some states apply aggregate theory and allocate gain based on where partnership owned property; Withholding and Composite Return issues * State Legislative Updates

 

Designed For:

CPAs in public practice and industry who need to keep abreast of the ever changing law of multistate tax

Prerequisite: Experience working with clients operating in multiple states

Advanced Prep: None

 

Speaker: Pam Davis-Vaughn, CPA

Vendor: Surgent McCoy

Field of Study: Taxes (2)

Level: Update

CPE Credit: 2 Hours

Acronym: MTPE

 

Registration Fees: $89

  

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