State & Local Tax Alert: Recent Developments in the State Taxation of Pass-Through Entities

In This Issue:

- Nonresident Owner Nexus

- Apportionment of Multistate Income

- Entity-Level Income Tax Withholding

- Composite Returns

- Entity-Level Taxes

- Issues Unique to S Corporations

- Miscellaneous Issues: P. 19-23

- Excerpt from Nonresident Owner Nexus:

Chief Administrative Law Judge Bill Thompson of the Alabama Department of Revenue upheld the imposition of the state’s mandatory composite income tax on an Alabama LLC owned in part by a nonresident who resided abroad. In his ruling, Judge Thompson reasoned that it was irrelevant whether the state had jurisdiction over the nonresident member , who lived in Greece, because the statutory composite filing/payment requirement was imposed on the LLC, which clearly had a sufficient nexus with the state to permit Alabama to enforce collection of the tax through the composite filing.

Please see full report below for more information.

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