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 course 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 has been making SALT less taxing for thousands of businesses over the last 25 years. As a director of the... | Read More
Ms. Roberts has been making SALT less taxing for thousands of businesses over the last 25 years. As a director of the SALTovation team at TaxOps, she is at the table-and in the weeds-helping guide dynamic businesses through compliance and strategic planning that minimizes risk and strengthens tax positions. She entered accounting with Andersen Worldwide/Andersen LLP, where she honed her state and local tax experience. She added stints at KPMG and Deloitte before moving in-house with a Fortune 500 company, managing State and Local Tax Administration. Before joining TaxOps, she led the national SALT practice at a regional firm. Stacey is a member of the Colorado Legislative Task Force Concerning Tax Policy and a frequent speaker and author on SALT issues for industry and professional organizations, including the Journal of State Taxation, Strafford Publishing, and more.
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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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