• videocam Live Webinar with Live Q&A
  • calendar_month September 1, 2026 @ 1:00 PM ET/10:00 AM PT
  • 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

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

Marc Gordon
State and Local Tax Senior Manager
TaxOps

Mr. Gordon brings over a decade of specialized experience in state and local tax to mid-market businesses across the country. With deep expertise in both income tax and sales and use tax, he serves as an outsourced SALT resource for CFOs, controllers and business owners who need a knowledgeable, hands-on partner to manager their most complex and pressing state and local tax challenges. Mr. Gordon's technical range spans the full spectrum of state and local tax needs: income tax compliance, sales and use tax support, nexus and taxability analysis, exposure modeling, voluntary disclosure and amnesty programs, and audit and notice defense. He works across all industries, recognizing that businesses of every kind accumulate state and local tax exposure and that finding it, resolving it, and charting a clear path forward is where he delivers the most value. 

Benjamin Wirth
Senior Manager
TaxOps

Mr. Wirth is a senior tax manager with over 12 years of public and private experience in partnership and corporation tax issues. He manages the delivery of tax consulting services to a wide range of clients, focusing on flow-through entities, entity structure, and transaction planning. Mr. Wirth has prior experience with corporate compliance and income tax reporting under ASC 740. He provides strategic tax consulting services to businesses at all stages of the business life cycle, from start-up to liquidation, assisting with the analysis of taxable and non-taxable acquisitions, restructuring, monetizing events, and interpreting tax sections in partnership operating agreements.

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

Date + Time

  • event

    Tuesday, September 1, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Partnership nexus

II. Allocation vs. apportionment of partnership income

A. Aggregate vs. entity approach

B. Business vs. nonbusiness income—differing state approaches

C. States taking a unitary approach

III. State withholding

The panel will discuss the following and other critical issues:

• State nexus and filing requirements

• Understanding unitary relationships between tiered pass-through entities

• Business/nonbusiness income determination at partner vs. partnership level

• Apportionment vs direct allocation of tiered income

• Application of state modifications from federal reporting

• State withholding, Composite Returns, and PTE

• Record-keeping, documentation, and K-1 best practices


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 at mid-level within the organization, preparing state tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of multistate partnership structures and in identifying business vs. nonbusiness income in multistate partnerships; familiarity with various state approaches to determine partnership income: aggregate vs. entity, unitary factor analysis, and partner vs. partnership income.

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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