Advanced Multistate Taxation of Partnerships, Individual Partners, and SALT PTE Elections

Business vs. Nonbusiness Income Characterization, Reconciling Conflicting State Tax Treatments, and More

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, December 7, 2021

Recorded event now available

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Course Materials

This course will give partnership tax advisers a comprehensive exploration into advanced multistate tax issues facing partnerships with income or operations in multiple states. The program will provide tax advisers and professionals with a detailed and practical guide to critical state tax issues and trends impacting individual partners owning shares of multistate partnerships. The panel will discuss critical questions such as the evolving state Pass-through Entity (PTE) elections and considerations for the owners.


One of the more challenging areas of multistate tax practice is the taxation of partners in partnerships conducting activities in more than one state. Navigating various states' treatment of partnerships, particularly their nonresident partners, can result in unforeseen tax consequences and compliance burdens. Tax advisers must resolve several critical issues to report partnership income accurately.

Determining whether the partnership's activities create nexus within the state, attributing the character of partnership income as active business income or passive investment income, and deciding whether the partnership elects to file a composite return or withhold tax are just some of the challenges faced by tax advisers. Reconciling various states' approaches to taxation of multistate partnerships and partners creates additional complexity in tax reporting and planning.

Determining whether the character of partnership income is at the partnership level or the partner level is crucial. Very few states have issued any guidance regarding where to make that income determination. Some states that have addressed the question have split results. Because taxpayers must apportion business income and allocate nonbusiness income to the source state, the tax results vary from state to state regarding the proper taxation of partnership income.

Since the IRS issued Notice 2020-75, several states have enacted Pass-through Entity Elections. These elections are meant to benefit the individual owners of the partnership, but there are several considerations before making the elections.

Listen as our experienced panel offers a comprehensive view of states' approaches to taxing partnership income.



  1. Allocation vs. apportionment of partnership income
  2. Business vs. nonbusiness income: differing state approaches
  3. States requiring withholding on nonresident partners
  4. State Pass-through entity elections


The participants will gain knowledge on the following critical issues:

  • State sourcing and taxation of income
  • State pass-through entity elections and related considerations


Arasu, Elil
Elil Shunmugavel Arasu

Managing Director, GWDC SALT Practice Leader

Ms. Arasu has more than 15 years of state tax consulting experience within a public accounting environment and...  |  Read More

Goldstein, Taryn
Taryn Goldstein, JD, LLM

SALT Managing Director

Ms. Goldstein leads the BDO Florida State and Local Tax practice as well as the southeast Credits and Incentives...  |  Read More

LaRosa, David
David LaRosa

SALT Senior Manager

Mr. LaRosa has 10 years of both federal and state tax experience, primarily at a big 4 accounting firm. He has...  |  Read More

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