State Taxation of Pass-Through Entities: General Principles (Portfolio 1500)
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This Portfolio considers the state taxation of hybrid entities that combine liability protection of a corporation with pass-through treatment via classification as a partnership.
Description
The Tax Management Portfolio, State Taxation of Pass–Through Entities: General Principles describes and compares the state tax provisions applicable to the most commonly used pass–through entities; the different types of participants in such entities; jurisdictional issues presented by nonresident and corporate participants; the application of state allocation and apportionment rules to pass–through entities and their participants; and various mechanisms used by the states to increase compliance with filing and tax payment obligations.
This Portfolio identifies important issues and differences in the approaches taken by the states that help aid you in structuring the entity in the most tax–advantaged manner, rather than attempting to catalogue each of the specific state tax rules applicable to pass–through entities and their participants.
Table of Contents
1500.01. INTRODUCTION
1500.02. PARTNERSHIPS
1500.03. TREATMENT OF PARTNERSHIP ENTITY
1500.04. TAXATION OF DISTRIBUTIVE SHARES OF PARTNERS
1500.05. CORPORATE PARTNERS
1500.06. NONRESIDENT PARTNERS
1500.07. RESIDENT PARTNERS
1500.08. TAXATION OF DISPOSITION OF PARTNERSHIP INTEREST
1500.09. S CORPORATIONS
1500.10. TREATMENT OF S CORPORATION ENTITY
1500.11. TAXATION OF NONRESIDENT S CORPORATION SHAREHOLDERS
1500.12. TAXATION OF RESIDENT S CORPORATION SHAREHOLDERS
1500.13. LIMITED LIABILITY COMPANIES
1500.14. OTHER PASS–THROUGH ENTITIES
Partner
Cooley LLP
Of Counsel
Sutherland Asbill & Brennan LLP