State Taxation on the Sale of Pass-Through Entity Interests
Sourcing Issues, Tiered Entities, Apportionment vs. Allocation, Residents vs. Nonresidents, Circumventing the SALT CAP
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will explain the issues practitioners encounter when reporting and taxing the sale of an interest held in a pass-through entity (PTE). Our panel of SALT veterans will discuss how types of owners, residency, and various state approaches (or lack thereof) impact these calculations, including examples of taxation in specific states.
Outline
- Flow-through entities
- Determining nexus
- Determining state taxable income
- Specific sourcing issues
- Gain on sales of interests
- Classification as asset sale
- Sales of intangibles
- Other issues
- Other entity-level taxes
- Circumventing SALT cap
Benefits
The panel will review these and other critical issues:
- Which states continue to recognize technical terminations and the related SALT issues
- Which states are a member of the MTC (Multi-State Compact) and the related PTE sales methodology
- How asset sales and stock sales treatment differs among states
- How residency impacts state reporting of disposition income
- How ownership type (individual, entity, tiered entity) impacts state taxation of PTEs
Faculty
Stacey L. Roberts, CPA
State and Local Tax Director
TaxOps
Ms. Roberts finds the singular state and local tax (SALT) area fascinating and is energized by the daily challenges to... | Read More
Ms. Roberts finds the singular state and local tax (SALT) area fascinating and is energized by the daily challenges to design solutions that improve business tax outcomes. With 20+ years of public and private sector accounting experience, both practical and in management, she’s gained the essential business acumen necessary to be a key advisor to clients. Ms. Roberts works closely with business clients managing all compliance issues related to state income/franchise, state and local sales and use, real and personal property and unclaimed property taxes for flow through entities and C corporations; identifying planning opportunities and state and local credits and incentives; and, mitigating state and local tax controversy issues with auditors and taxing jurisdictions.
Stacey began her career with Andersen Worldwide/Andersen LLP, where she began to hone her state and local tax experience. She added stints at KPMG and Deloitte before moving in-house with Ball Corporation as their manager of State and Local Tax Administration. An interlude with a regional tax firm followed before Stacey joined TaxOps. Ms. Roberts is a frequent speaker and author on SALT issues for industry and professional organizations including the Denver Tax Institute, Product PowerUp, NowCFO and more.
Meredith Smith, CPA
State and Local Tax Manager
TaxOps
Ms. Smith expertly weaves real-life examples into why business taxpayers, tax professionals, and tax providers should... | Read More
Ms. Smith expertly weaves real-life examples into why business taxpayers, tax professionals, and tax providers should care about complex state and local tax (SALT) issues. This knowledge comes from expertly navigating the web of tax laws governing SALT issues for 15 years. From working with clients inside their business, she knows the questions, issues and strategies for resolution that keep businesses on the tax compliance track. Ms. Smith combines technical knowledge and in-depth industry understanding in performing nexus studies, identifying areas of risk, and designing sustainable planning opportunities for achieving tax-specific business goals. Her practice covers state income tax, property tax, sales and use tax, and business incentives and credits. Prior to TaxOps, Ms. Smith was a member of the SALT practice at KPMG, serving large, multi-jurisdictional corporations and multi-tier partnerships across industries.
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