Multistate Tax Treatment of Multi-Tier Partnerships: Navigating State Rules For Nonresident Tiered Pass-Through Entities

Determining Treatment of Lower-Tier Apportionment Factors, Meeting Withholding and Composite Return Requirements

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

Thursday, August 31, 2017 (in 10 days)
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

This webinar will provide tax advisers and compliance professionals with a practical guide to navigating the multistate reporting complexities involved 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.


A significant challenge for tax advisers to tiered partnerships is determining various states’ tax treatment of the tiered entities, particularly when a lower-tier partnership is located in a different state than the upper-tier owner. Because of the inconsistency in various state treatments, tax advisers often face complex, sometimes conflicting, rules in determining how the upper-tier entity resident state will treat pass-through items of income and loss from lower-tier entities.

Advisers to upper-tier partnerships must determine how the entity’s lower-tier pass-through items are treated in the resident state. Ascertaining whether the lower-tier partnership’s apportionment factors flow through to the upper-tier entity materially affects the income/loss calculations of the partnership.

Likewise, navigating various states’ withholding requirements and determining when a lower-tier’s resident state allows, or mandates, composite filings is also a crucial and difficult task.

Tax advisers need to fully grasp the significant factors in determining various states’ tax treatment of multi-tier partnerships when the lower-tier partnership is non-resident.

Listen as our experienced panel offers a practical guide to navigating multistate complexities and approaches to taxing tiered partnerships with nonresident lower-tiers.


  1. Identifying multi-tier partnerships with multistate filing requirements
  2. How to determine whether lower-tier apportionment factors flow through to upper-tier partner
  3. Withholding requirements
  4. Composite return rules and exceptions for multi-tier partnerships


The panel will discuss these and other important 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?

Learning Objectives

After completing this course, you will be able to:

  • Identify various state approaches to flow through treatment of apportionment factors from lower-tier to upper-tier partnerships to calculate partnership income and loss
  • Recognize various state approaches to withholding requirements on tiered partnerships
  • Discern which states permit filing of composite returns for tiered partnerships and which require composites
  • Determine states that permit tax credits and other attributes to flow through from lower-tier to upper-tier partnerships


Karen A. Lake, CPA, Associate Director of Tax Services
Berkowitz Pollack Brant Advisors and Accountants, Ft. Lauderdale, Fla.

Ms. Lake has nearly 20 years of experience focusing on helping businesses and individuals develop their tax structure and navigate complex state and local scenarios.  She has specialized experience in state tax risk, improving cash flow and federal and state credits and incentives. Her areas of focus include complex transactional planning, credits and incentives, entity structuring and design, income / franchise, sales and use tax, SALT audit defense and appeals, and SALT minimization strategies. Previously, she was a senior advisor in a Big 4 public accounting firm, a member of corporate tax department and a state auditor.

Michael Hirsch, JD, LLM, Senior Manager of Tax Services
Berkowitz Pollack Brant Advisors and Accountants, Ft. Lauderdale, Fla.

Mr. Hirsch specializes in state, local, and corporate taxation. He helps clients with structuring, compliance, state tax matters, involving corporations, partnerships, limited partnerships and limited liability companies. Throughout his career, he has worked in the SALT practice of a Big-4 public accounting firm and in the corporate tax department of an international security systems corporation.

Richard Cabrera, Corporate Tax Senior Manager
Berkowitz Pollack Brant Advisors and Accountants, Ft. Lauderdale, Fla.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $147.00

Live Webinar & CPE Processing $182.00

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 complex state income tax forms and schedules for pass-through entities; supervisory authority over other preparers/accountants. Knowledge and understanding of withholding requirements, composite returns, nonresident filing, and payment of taxes by pass-through entities; familiarity with tiered partnership structures

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.


Recorded Event

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