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
Recording of a 110-minute CPE webinar with 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.
Outline
- 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
Benefits
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
Faculty

Jonathan Weinberg, JD, LLM
Principal
WithumSmith+Brown
Mr. Weinberg is a Principal with over 25 years of experience practicing State and Local Tax with extensive... | Read More
Mr. Weinberg is a Principal with over 25 years of experience practicing State and Local Tax with extensive experience with income/franchise tax, sales and use tax, voluntary disclosure agreements, audit defense, real estate transfer tax, individual income tax residency and domicile issues. He has served clients in financial services, media, technology, pharmaceuticals and biotech, retail, manufacturing, professional services, government contractors, and not-for-profit organizations. Mr. Weinberg has developed relationships with several state tax departments and voluntary disclosure units.
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Brian D. Pedersen
Managing Director
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.
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