Unitary Combined Reporting Rules for Multistate Partnerships: Reconciling Conflicting State Tax Requirements
State Requirements for Flow-Through of Apportionment Factors, Permissible Allocations, Corporate Partner Treatment
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide partnership tax advisers with a thorough and practical guide to the unitary reporting rules for partnerships with income or operations in multiple states. 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.
Outline
- Allocation vs. apportionment of partnership income
- Business vs. nonbusiness income--differing state approaches
- Aggregate vs. entity approach
- Unitary vs. non-unitary filing rules
- States providing the option of a composite return
- The state requiring withholding on nonresident partners
Benefits
The panel will discuss these and other critical questions:
- Which states require business/nonbusiness income determination at partner vs. partnership level
- Which states require unitary filings, and under what thresholds?
- Determination of partnership income on aggregate basis vs. entity basis
- Apportionment under the aggregate approach
- State withholding
Faculty
Elil Shunmugavel Arasu
Managing Director, GWDC SALT Practice Leader
BDO USA
Ms. Arasu has more than 15 years of state tax consulting experience within a public accounting environment and... | Read More
Ms. Arasu has more than 15 years of state tax consulting experience within a public accounting environment and concentrates on income and franchise tax issues such as nexus, state tax base modifications, apportionment of income, business/non-business income, unitary taxation, gross receipt taxes, allocation of partnership items, and state filing options. Ms. Arasu consults on all aspects of state income tax, including participating in M&A transactions, due diligence reviews, representation on state tax controversy matters, and assisting companies with state tax compliance and state tax accrual reviews. She has worked with Fortune 1000 and mid-size companies in industries such as manufacturing, retail, healthcare, hospitality, real estate, technology, and transportation.
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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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