BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month June 18, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Corporate Tax
  • schedule 110 minutes

State Taxation of Partnership Interest Sales: Recent Legislation, State Apportionment and Allocation Methods, Business vs. Nonbusiness Income

$247.00

This course is $0 with these passes:

CPE
ALL
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Description

In the simplest circumstances and former times, a taxpayer might only be taxed on the sale of a partnership interest in their resident state. Applying new and evolving rules (e.g., investee apportionment rules, market-based sourcing), many states increasingly determine where whether a taxpayer is engaged in business activities within the state to determine if a sale is taxable by the state.

 

For SALT practitioners and multistate businesses, these determinations are onerous. As with all SALT matters, state treatment of partnership interest sales varies. Treatment of the gain in specific states differs based on the type of members or partners (individual, corporate, etc.) that comprise the LLC or partnership, whether the sale is treated as business or nonbusiness income, and the corresponding apportionment and/or allocation rules. Unfortunately, the lack of consistency among states can subject these transactions to double taxation.

 

Legislation in this area is fluid. Multistate pass-through entities and their advisers need to grasp the rules surrounding state taxation of the sales of partnership interests.

 

Listen as our authoritative panel of state and local income tax veterans examines the inconsistent but common guidelines states invoke to tax the sale of partnership interests.

Presented By

John Damin
Managing Director
BDO USA

Mr. Damin is a Managing Director whose primary focus is in state and local income/franchise tax. His state tax experience, spanning more than a decade, includes tax planning, tax compliance, controversy, state tax provision review, and sales and use tax.

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Andre Thickening
Senior Manager - State & Local Tax Services
BDO USA

Mr. Thickening is a Senior Manager - State & Local Tax Services at BDO USA. 

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Credit Information

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

Date + Time

  • event

    Wednesday, June 18, 2025

  • schedule

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

I. SALT taxation of partnership interest sales: introduction

II. Identifying the seller

III. Which states may tax the gain

IV. Business vs. nonbusiness income

V. Relevant apportionment or allocation rules

VI. Taxing the sale

A. Entity-level taxation

B. Treatment as a single-member LLC

VII. Technical developments affecting a sale


The panel will cover these and other key issues:

  • Determining apportionment and allocation rules for specific states
  • State trends and recent rulings impacting the sale of partnership interests
  • Identifying specific state criteria for taxing nonresident sales of partnerships
  • How potential double state taxation affects the disposition of a partnership

After completing this course, you will be able to:

  • Determine states' methods for taxing sales of partnership interests
  • Ascertain how certain partnership sales can be subjected to double state taxation
  • Identify the seller of a partnership interest as defined in certain states
  • Decide how current state legislation impacts sells of partnership interests


  • 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 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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