Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners
Business vs. Nonbusiness Income Characterization, Aggregate vs. Entity Determination, and More

Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Corporate Tax
- event Date
Thursday, August 7, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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.
Faculty

Ms. Roberts has been making state and local tax (SALT) less taxing for thousands of businesses over the last 25 years. As a director of the SALTovation team at TaxOps, she guides dynamic businesses through compliance and strategic planning focused on minimizing risk and strengthening tax positions. Ms. Roberts honed her specialty at Andersen Worldwide/Andersen LLP, KPMG and Deloitte before moving in-house with a Fortune 500 company to administer state and local tax. She has also led the national SALT practice at a regional firm. Ms. Roberts is a member of the Colorado Legislative Task Force Concerning Tax Policy and a frequent speaker, instructor and author on SALT issues for industry and professional organizations.

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 nearly 20 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. She is a frequent speaker and the host of the SALTovation podcast, a podcast series featuring leading voices in states and local tax. Listen in on your favorite channel: https://saltovation.captivate.fm/listen.
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.
Outline
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
Benefits
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
NASBA Details
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.

Strafford Publications, 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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