Multistate Flow-Through Entity Income Taxation

General Description:

This course provides a summary of the state flow-through entity taxation, including partnerships and S corporations, of multistate corporations.

Learning Objective:

After completing this course the participant will be able to:

• Recognize key U.S. constitutional limits to state taxation and relate them to historical developments and present-day state tax policies.
• Apply nexus rules and Public Law 86-272 and relate these rules to leading-edge business models, states that require business/nonbusiness income determination at partner vs. partnership level, and determination of partnership income on an aggregate basis vs. entity basis.
• Compute apportionment, including interpreting and applying apportionment under the aggregate approach, reconciling different states' unitary factor analysis, sales throwback rules with respect to the sale of tangible personal property, and market-sourcing rules for service revenue.
• Explain common state income tax issues with pass-through entities.
• Describe state tax implications of recent federal tax reform, including: for pass-through entity tax states, state withholding and composite tax returns, and credit for taxes paid in resident state; and for partnership audits, states that do not recognize typical pass-through entity taxation, and recordkeeping, documentation, and workpapers.

Instructors:

Stacey Roberts, CPA, is a partner in the SALTovation team at TaxOps in Denver. She works closely with business clients managing all compliance issues related to state income/franchise and sales and use tax for flow through entities and C corporations across various industries; identifying planning opportunities and state and local credits and incentives; and mitigating state and local tax controversy issues with auditors and taxing jurisdictions. Her 25 years of experience in state and local tax also includes three of the Big Four accounting firms and a Fortune 500 company. She is a member of the Colorado Legislative Tax Policy Task Force through 2026 and frequently presents and writes on SALT issues.

Related Courses: