Sourcing Income from Passthrough Entities & Developments Since Metropoulos; 2023 Annual Meeting of the Tax Bar and Tax Policy Conference

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Sourcing Income from Passthrough Entities & Developments Since Metropoulos; 2023 Annual Meeting of the Tax Bar and Tax Policy Conference

Taxation Law Section

Credit(s):

1 Legal Specialization in Taxation Law
1 Participatory MCLE Credits

Course Number:

TAX_AM_2023_08

Original Program Date:

November 2, 2023

Duration:

1 hour 2 minutes

Access:

Available for 3 months after Registration

Passport:

This product is Passport Eligible

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Category: Taxation, Closed Captioned Courses

Category: Taxation, Closed Captioned Courses (show less)

This panel will focus on the interplay between the California personal income tax law and the tax law for entities in the context of sourcing income—namely, income from derived from an ownership interest in a passthrough entity or the sale of that ownership interest. While complex questions have always surrounded this topic, new life was breathed into the issue for California tax practitioners when the Office of Tax Appeals published its Metropolous decision in 2019. Specific items discussed in this panel will include new developments in the case law (both of California and other states), the apportionment rules for flowthrough entities, and considerations from other areas of tax law such as unity and business vs. non-business income.

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