Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

Business vs. Nonbusiness Income Characterization, Aggregate vs. Entity Determination, and More

A live 110-minute CPE webinar with interactive Q&A


Thursday, October 19, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, September 22, 2017


This webinar will provide tax advisers and professionals with a detailed and practical guide to critical state tax issues and trends impacting partners owning shares of multistate partnerships. The panel will discuss key 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.

Description

Corporate partners in multistate partnerships face significant tax challenges. Critical among the problems tax advisers must resolve is determining whether a partnership creates nexus for a nonresident partner. This determination may materially impact filing obligations, including combined reporting and P.L. 86-272 positions, as well as the application of throwout and throwback rules.

Also crucial is whether the character of partnership income, e.g., business or nonbusiness, must be determined at the partnership level, or at the partner level. Very few states have issued any guidance as to where that income determination must be made, and those states that have addressed the question have split results. Because business income must be apportioned, while nonbusiness income must be allocated to the source state, the tax results vary from state to state as to the proper taxation of partnership income. Additional complexities arise depending on whether a state has adopted the "aggregate" or "entity" approach to apportionment of partnership income. These determinations may materially impact both the computation of state blended rates for provision calculations and whether the corporation must remit payment to a particular state.

Likewise, various states have adopted different reporting regimes when it comes to withholding or composite return obligations. Corporate tax professionals must know the complex rules to avoid negative tax consequences in multistate partnership scenarios.

Listen as our experienced panel offers a comprehensive view of states’ approaches to taxing corporations on multistate partnership income.

Outline

  1. Partnership Nexus
  2. Allocation vs. apportionment of partnership income
    1. Aggregate vs. entity approach
    2. Business vs. nonbusiness income—differing state approaches
    3. States taking a unitary approach
  3. State withholding

Benefits

The panel will discuss these and other critical issues:

  • Nexus implications
  • States that require business/nonbusiness income determination at partner vs. partnership level
  • Determination of partnership income on aggregate basis vs. entity basis
  • Apportionment under the aggregate approach
  • Reconciling different states’ unitary factor analysis
  • State withholding
  • Recordkeeping/documentation/workpapers

Learning Objectives

After completing this course, you will be able to:

  • Identify nexus concerns in a multistate context
  • Differentiate allocation vs. apportionment of partnership income
  • Discern aggregate vs. entity approach for determining partnership income
  • Select the states that take the unitary approach

Faculty

Dennis Rimkunas, Partner
Jones Day, New York

Mr. Rimkunas focuses his practice on tax planning and litigation relating to state and local tax matters for corporations, partnerships, and individuals. He advises clients on state and local tax implications of restructurings, refinancings, mergers, acquisitions, spin-offs, and asset dispositions. He also represents clients at all stages of the state and local tax controversy process and regularly assists clients on unclaimed property issues relating to audits, voluntary disclosure agreements, planning and structuring, and general compliance policies and procedures.

Michael J. (Mike) Wynne, Partner
Jones Day, Chicago

Mr. Wynne has more than 30 years of experience in state and local tax litigation, planning, legislative, and regulatory work in Illinois and throughout the United States concerning income, sales, telecommunications, ad valorem (according to value), and other taxes and unclaimed property laws. His practice includes audit, litigation, and appellate practice in matters such as state False Claims Act tax defense, state tax refund class action defense, real property tax exemption litigation for health care facilities and government facility developers, individual residency cases, telecommunications excise tax, sales and income taxes, and multiple unclaimed property audits, voluntary disclosures, and advice.


Registration per Person for Live Event

Live Webinar $197.00

Includes Early Discount Savings of $50.00 (through 09/22/17)

Live Webinar & CPE Processing $232.00

Includes Live Webinar Early Discount Savings of $50.00 (through 09/22/17)


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing state tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of multistate partnership structures and in identifying business vs. nonbusiness income in multistate partnerships; familiarity with various state approaches to determine partnership income: aggregate vs. entity, unitary factor analysis, and partner vs. partnership income.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $197.00
Available 48 hours after the live event

Includes Early Discount Savings of $50.00 (through 09/22/17)

How does this work?

Recorded Audio Download (MP3) $197.00
Available 24 hours after the live event

Includes Early Discount Savings of $50.00 (through 09/22/17)

How does this work?

DVD (Slide Presentation with Audio) $197.00 plus $9.45 S&H
Available ten business days after the live event

Includes Early Discount Savings of $50.00 (through 09/22/17)

How does this work?


Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $294.00

Includes Special Savings of $200.00 (through 09/22/17)

Live Webinar & Audio Download $294.00

Includes Special Savings of $200.00 (through 09/22/17)

Live Webinar & DVD $294.00 plus $9.45 S&H

Includes Special Savings of $200.00 (through 09/22/17)


NASBA CPE Sponsor

National Registry of CPE Sponsors

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Early Registration
Discount Deadline
September 22, 2017
(about 9 hours)

or call 1-800-926-7926

Can't Attend the Live Program?

CPE Credit

Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.

or call 1-800-926-7926

EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

or call 1-800-926-7926

Customer Reviews

I liked that the PowerPoint slides would automatically change as the speaker's presentation progressed.

Zeeshan Elahi

Ryan

It was an excellent program!!

Marni Odermann

Supervalue

I found the presenters to be very experienced and the Q&A's to be particularly useful.

Mike O'Brien

American Eagle Outfitters

Offered different view points and real life, practical examples.

Angela Chretin

Northrop Grumman

The webinar was fast paced and comprehensive.

Lorraine Round

SAP

or call 1-800-926-7926

State Income Tax Advisory Board

David Adler

Director of Multistate Tax Services

Deloitte Tax

Elizabeth Bowman

Tax Research Analyst

ADP Tax Credit Services

Stephanie Anne Lipinski-Galland

Partner

Williams Mullen

Don Griswold

Executive Tax Counsel

Berkshire Hathaway Tax Group

Walter Pickhardt

Partner

Faegre Baker Daniels

Richard Pomp

Professor of Tax Law

University of Connecticut

Michael Press

President

Scout Economics

Tammy Propst

President

taxadvantagegroup

Richard Weiss

Tax Research Manager

ADP Tax Credit Services

Thomas Zaino

Managing Member

Zaino Hall & Farrin

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.