Recent Developments In State Taxation of Pass-Through Entities

State and local taxation of pass-through entities continues to present complex issues for the owners of those entities, especially when the pass-through entities are conducting business in multiple states. Compared with resident owners over which a state has jurisdiction because of their physical presence in the state, nonresident owners of pass-through entities are presented with more difficult issues. As a way to collect additional revenue and potentially avoid difficult constitutional questions involving how to tax nonresidents, many states have enacted entity-level taxes or withholding or composite return requirements.

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