Multistate Tax Treatment of Multi-Tier Partnerships: Ingesting PTET in a Multi-Tier Entity
Determining Treatment of Lower-Tier Apportionment Factors, Meeting Withholding and Composite Return Requirements
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This course will provide tax advisers and compliance professionals with a practical guide to navigating the multistate reporting complexities in multi-tiered partnerships. The panel will outline various state rules governing apportionment of income from lower-tier pass-through entities, withholding requirements, and composite return provisions. The panel will also discuss state approaches to honoring IRC 743(b) adjustments from the upper-tier to the lower-tier partnerships.
- Identifying multi-tier partnerships with multistate filing requirements
- How to determine whether lower-tier apportionment factors flow through to an upper-tier partner
- Withholding requirements
- Composite return rules and exceptions for multi-tier partnerships
The panel will discuss these and other vital questions:
- Which states allow lower-tier partnership's apportionment factors to flow through to the upper-tier partner?
- How does the presence of a tiered partnership impact withholding requirements for nonresident partners?
- Impact of a partnership's status as a tiered entity on composite return requirements
- What states allow tax attributes to flow through to the upper-tier partnership?
- The ability to use Multi-Tier entities and, if applicable, the allocations from MTPs to mitigate SALT
- How the SALT interacts with the PTET regimes
- Restructuring and other transactions to make your Multi-Tier entity eligible for the PTET of the applicable state
Jonathan Weinberg, J.D., LL.M.
Mr. Weinberg has extensive experience with income/franchise tax, sales and use tax, real estate transfer tax, and... | Read More
Mr. Weinberg has extensive experience with income/franchise tax, sales and use tax, real estate transfer tax, and individual income tax residency and domicile issues.Close
Brian D. Pedersen
Alvarez & Marsal Taxand
Mr. Pedersen is a Managing Director with Alvarez & Marsal Taxand, LLC in Houston. He leads the firm’s State... | Read More
Mr. Pedersen is a Managing Director with Alvarez & Marsal Taxand, LLC in Houston. He leads the firm’s State Income Tax Competency team and is also a member of the core bankruptcy and troubled companies team. Mr. Pedersen brings more than 30 years of experience in advising on multi-state income tax, sales and use tax, and property tax matters.Close
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CPE processing must be ordered prior to the event. See NASBA details.
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CPE credit is not available on downloads.