Multistate Tax Treatment of Multi-Tier Partnerships: State Tax Issues for Nonresident Tiered Pass-Through Entities
Reconciling State Recognition Rules, Apportionment from Lower-Tier Pass-Through Entities, Withholding Requirements
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel, advisers, and compliance professionals with a practical guide to navigating the state tax complexities involved in multi-tiered partnerships. The panel will discuss various state rules governing apportionment of income from lower-tier pass-through entities, withholding requirements, and state approaches to honoring IRC 743(b) adjustments from the upper-tier to lower-tier partnerships.
Outline
- Identifying multi-tier partnerships with multistate filing requirements
- Determining whether lower-tier apportionment factors flow through to an upper-tier partner
- Withholding requirements
- Composite return rules and exceptions for multi-tier partnerships
Benefits
The panel will review these and other vital questions:
- State rules allowing lower-tier partnership's apportionment factors to flow through to the upper-tier partner
- The impact of tiered partnerships on withholding requirements for nonresident partners
- The impact of a partnership's status as a tiered entity on composite return requirements
- States allowing tax attributes to flow through to the upper-tier partnership
Faculty
William H. Gorrod
Of Counsel
Morrison & Foerster
Mr. Gorrod focuses his practice on state and local tax planning, compliance, and corporate transactions on a multistate... | Read More
Mr. Gorrod focuses his practice on state and local tax planning, compliance, and corporate transactions on a multistate basis. He also represents clients in state and local tax controversies throughout the United Statess. Mr. Gorrod regularly advises clients on matters pertaining to state and local income and franchise taxes, gross receipt taxes, sales and use taxes, payroll taxes, and real estate transfer taxes and represents clients in audits, administrative appeals, voluntary disclosure agreements, penalty abatements, and amnesties. His clients include large corporations and flow-through entities across a wide range of industries, including technology, financial services, retail, and media.
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Cosimo A. Zavaglia
Partner
Morgan Lewis
Mr. Zavaglia advises corporations, partnerships, and individuals on state and local tax controversy, planning, and... | Read More
Mr. Zavaglia advises corporations, partnerships, and individuals on state and local tax controversy, planning, and transactional matters. He routinely represents clients in high-stakes state and local tax audits, appeals, and litigations in matters throughout the United States, including defending clients in state False Claims Act cases and sales and use tax, individual residency, withholding tax, corporate income tax, and real estate transfer tax audits and disputes. He also advises clients on developing state and local tax planning strategies for corporate acquisitions, dispositions, restructurings, and mergers.
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