State Pass-Through Entity Taxation Regimes: Case Studies on Various Traps That PTEs and Their Owners Can Fall Into
Recording of a 110-minute CPE webinar with Q&A
This course will discuss states' pass-through entity (PTE) taxation regimes and when and how to elect PTE taxation in applicable states, as well as analyze the ultimate taxation of owners to mitigate taxes paid.
Outline
- Background
- Mandatory PTE taxation
- Elective PTE taxation
- Specific state taxation regimes
- Analyzing the impact of PTE taxation on owners
- Best practices
Benefits
The panel will cover these and other critical issues:
- When does the PTE and/or the owners have to include a state tax refund in Federal gross income?
- When should the PTE deduct the state PTE taxes for Federal income tax purposes?
- Can an owner of a PTE get allocated the ‘incorrect’ amount of the PTE tax expense?
- What happens to the owner’s tax benefit when the owner of a PTE has suspended losses?
- Should a PTE with trust owners make state PTE elections?
- Can an interest expense limitation under IRC Section 163(j) cause more state tax to be paid if state PTE elections are made?
- When a PTE sells its business are there circumstances where state PTE elections should not be made?
Faculty
Kimberly Capizzi, CPA
Managing Director, State & Local Tax
BDO USA
Ms. Capizzi works in the firm’s State and Local Tax Practice with more than 12 years of experience in public... | Read More
Ms. Capizzi works in the firm’s State and Local Tax Practice with more than 12 years of experience in public accounting, serving a wide array of clients, ranging from individuals to publicly traded corporations. She focuses much of her time on multistate organizations, including complex multi-tiered partnerships, ensuring clients meet all compliance requirements and deadlines. Most of Ms. Capizzi’s clientele are flow-through entities and she is well versed in the state tax issues specific to such entities. Additionally, Ms. Capizzi assists corporations and flow-through entities in designing and implementing structural enhancements to generate long-term state tax reductions and reduce state tax compliance requirements.
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Richard W. Spengler, CPA
National Technical Leader - State & Local Tax
BDO USA
Mr. Spengler's main area of focus is state income and franchise taxes with significant experience in the design and... | Read More
Mr. Spengler's main area of focus is state income and franchise taxes with significant experience in the design and implementation of legal entity structures that are more tax efficient. As a result of his unique background, he has had success in designing structures that both minimize the impact on his client’s operations while maximizing the tax savings received by the client. Mr. Spengler specializes in the design of structures that both complement the client’s underlying business and provide diversified tax savings. As such, he has successfully designed structures for clients that simultaneously reduce state income tax, Single Business Tax, franchise tax, sales & use tax and federal income tax while logically fitting within the way the business operates. In addition to restructuring work, Mr. Spengler also has significant experience with the analysis of tax return positions and with the subtle interaction between the Federal income tax framework and its impact on a client’s state income tax reporting. He has had a great deal of success with securing significant refunds for clients related to gray and misunderstood areas of the tax law.
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