Multistate Partnerships CPE

by | Jul 28, 2025 | Events, State and Local, Tax News | 0 comments

Join Partners Stacey Roberts and Meredith Smith at TaxOps for upcoming CPE on navigating various state taxation rules of corporate partners.

Multistate Partnerships: Navigating Various State Taxation Rules of Corporate Partners

Thursday, August 7, 2025 | 11:00 – 12:50 MT

Register

Stacey Roberts and Meredith Smith provide a practical guide to tax advisors and professionals on critical state tax issues and trends impacting partners owning shares of multistate partnerships. The instructors will discuss 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.

Outline

  1. Partnership nexus
  2. Allocation vs. apportionment of partnership income
  3. Aggregate vs. entity approach
  4. Business vs. nonbusiness income–differing state approaches
  5. States taking a unitary approach
  6. State withholding

Benefits

The instructors will review these and other 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

Instructor:

Stacey Roberts, CPA
Partner, TaxOps

Stacey 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. Stacey 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. Stacey 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.

Meredith Smith, CPA
Partner, TaxOps

Meredith 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. Meredith 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, Meredith 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 Show, a podcast series featuring leading voices in states and local tax. Listen in on your favorite channel: SALTovation Show. 

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