BarbriSFCourseDetails
  • videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Corporate Tax
  • schedule 110 minutes

Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

Business vs. Nonbusiness Income Characterization, Aggregate vs. Entity Determination, and More

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About the Course

Introduction

This course will provide tax advisers and professionals with a detailed and practical guide to critical state tax issues and trends impacting partners owning shares of multistate partnerships. The panel will discuss critical questions such as whether the character of pass-through income is determined at the partner or partnership level and whether the pass-through income must be considered on an "aggregate" basis or an "entity" basis.

Description

Corporate partners in multistate partnerships can't escape nexus. Among the significant tax challenges these partnerships face is determining whether a partnership creates nexus for a nonresident partner. Nexus may materially impact filing obligations, including combined reporting and P.L. 86-272 positions and throwout and throwback rules.

The character of partnership income, e.g., business or nonbusiness, also must be determined at the partnership level or the partner level. Very few states have issued any guidance on where to make the income determination, and those states that have addressed the question have mixed results.

Because business income must be apportioned, while nonbusiness income must be allocated to the source state, taxation of partnership income varies from state to state. Additional complexities arise depending on whether a state has adopted the "aggregate" or "entity" approach to the apportionment of partnership income. These determinations may materially impact the computation of state blended rates for provision calculations and whether the corporation must remit payment to a particular state.

Likewise, various states have adopted different reporting regimes regarding withholding or composite return obligations. Corporate tax professionals must know the complex rules to avoid adverse tax consequences in multistate partnership scenarios.

Listen as our experienced panel offers a comprehensive view of states' approaches to taxing corporations on multistate partnership income.

Presented By

Stacey Chamberlain, CPA
Principal
Aprio, LLP

Ms. Chamberlain is a State and Local Tax (SALT) professional with more than 25 years of experience in public and private sector accounting. Her specialties include state income and franchise tax, sales and use tax, and strategic tax planning for flow-through entities and C corporations across diverse industries. Ms. Chamberlain is passionate about designing solutions that improve business tax outcomes and mitigate risk, while identifying opportunities for savings and efficiency.

Meredith Smith
Principal
Aprio, LLP

Ms. Smith combines technical knowledge with an in-depth industry understanding of state and local tax (SALT) issues to help clients navigate the complexities of tax laws governing SALT issues. Her practice covers state income tax, sales and use tax, and state payroll tax. With more than 20 years of experience in SALT, Ms. Smith works with clients to design sustainable planning strategies that align with tax-specific business goals, while identifying risk areas and compliance requirements.

Credit Information
  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

Date + Time

  • event

    Thursday, August 7, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Partnership nexus

II. Allocation vs. apportionment of partnership income

III. Aggregate vs. entity approach

IV. Business vs. nonbusiness income--differing state approaches

V. States taking a unitary approach

VI. State withholding

The panel will discuss these and other critical issues:

  • Nexus implications
  • States that require business/nonbusiness income determination at partner vs. partnership level
  • Determination of partnership income on an aggregate basis vs. entity basis
  • Apportionment under the aggregate approach
  • Reconciling different states' unitary factor analysis
  • State withholding
  • Recordkeeping, documentation, and workpapers

Learning Objectives


After completing this course, you will be able to:

  • Identify nexus concerns in a multistate context
  • Differentiate allocation vs. apportionment of partnership income
  • Discern aggregate vs. entity approach for determining partnership income
  • Select the states that take the unitary approach
  • 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 attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of SALT taxation, nexus and apportionment as it applies to multi-state businesses.


BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

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