Mastering Multi-State Taxation of S Corporations: State Variances in Recognition of S Elections and QSSS

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

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Conducted on Thursday, August 13, 2015

Recorded event now available

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Course Materials

This course will provide tax preparers and advisers with detailed guidance on the most pervasive issues facing multi-state taxation of S corporations. The panel will detail those states that vary from automatic acceptance of the federal S election, review the composite return requirements, and discuss calculations, adjustments and filing requirements for those states where the S election fails and a composite return is not available. The panel will also outline state variances in tax treatments of Qualified Sub-Chapter S Subsidiaries (QSSS).


Multi-state taxation of S corporations presents significant challenges to tax preparers and advisers. Not every state follows the federal S election tax guidelines, and some states do not even recognize S corporations as pass-through entities in all circumstances. In addition to the lack of conformity in filing requirements and status, various states have different treatments of nonresident shareholders, and differing rules regarding composite returns and withholding.

Different states have different approaches to filing and withholding requirements when a resident S corporation has nonresident shareholders. While many states require composite returns, some states, such as Georgia, require all shareholders to consent to an S corporation tax filing, and require the corporation to file as a C corp absent that consent. Tax advisers must be fully aware of the filing and withholding issues that arise when an S corporation has a nonresident shareholder.

In addition to the overall lack of conformity between federal and states treatment of S corporations, there is divergence among various states on the recognition of QSSS. There are a number of states that do not recognize the QSSS, and tax advisers must understand the impact of nonrecognition.

Listen as our experienced panel provides a detailed exploration into the issues and opportunities related to the multistate taxation of S corporations.



  1. Current landscape of state treatment of S corporations
    1. States with full conformity with federal S election
    2. States with partial conformity with federal S election
    3. States with intentional nonconformity with federal S election
  2. S corporations with nonresident shareholders
  3. Apportionment and allocation questions
  4. Taxation of nonresident shareholders
  5. Composite return requirements


The panel will review these and other key issues:

  • What are the current state-by-state mechanics for nonresident S corporations?
  • What are the composite return and consent rules in the case of S corporations with nonresident shareholders?
  • What are the major state trends for QSSS recognition?
  • What calculations, adjustments and schedules need to be maintained in the case of multi-state filings where one state does not recognize S corporation status?


Karen Harriger Currie
Karen Harriger Currie

Jones Day

Ms. Currie’s practice involves a wide range of tax matters. Her roots are in multistate taxation and she also...  |  Read More

Glickman, Jeff
Jeff Glickman

Habif Arogeti & Wynne

Mr. Glickman is the partner-in-charge of his firm's State & Local Tax (SALT) practice. He has over 15...  |  Read More

Seiden, David
David Seiden, CPA

Citrin Cooperman

Mr. Seiden is the partner-in-charge of the firm’s State and Local Tax Practice, and brings more than 25...  |  Read More

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