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
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.
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
Arun Dubey
Managing Director
Green Hasson & Janks
Mr. Dubey, EA, is a member of GHJ's State and Local Tax Practice with a focus on state income and... | Read More
Mr. Dubey, EA, is a member of GHJ's State and Local Tax Practice with a focus on state income and franchise tax, sales tax, property tax and indirect tax. He has over 10 years of tax experience specializing in multistate tax. Mr. Dubey has experience with multistate corporations, partnerships, hedge funds, private equity funds and fund of funds. At GHJ, he focuses on C-corp, S-corp, real estate, manufacturing and food and beverages clients. Mr. Dubey also specializes in tax due diligence in the event of mergers and acquisitions. He provides his tax expertize in nexus determination for income tax as well in sales tax economic nexus thresholds. Mr. Dubey provides guidance on city business taxes such as Los Angeles business license tax, San Francisco gross receipts tax and Santa Monica business license tax.
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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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Early Discount (through 08/22/25)
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CPE On-Demand